Judicial Disqualification Resource Center


Judicial Disqualification in Guam

guamIn Guam, judicial disqualification is controlled by 7 GCA § 6105 et seq. In particular, 7 GCA § 6107 provides, in pertinent part, that whenever a judge “neglects or fails to declare his or her disqualification,” any party to the proceeding “may present to the court and file with the clerk a written statement” setting forth the facts constituting the ground for disqualification. The statute is derived from California law. See People v. Johnny, 2006 Guam 10, P12 (Guam 2006).

In 2013 a working group comprised of Guam judges and others undertook a review of the process of judicial disqualification in Guam trial courts and the appellate court. The group concluded that the judicial disqualification process would likely be more efficient if standard forms were to be used in judicial disqualification situations. The group developed draft forms – and, following a review and comment period — Guam’s Supreme Court adopted standard judicial disqualification forms for the Superior Court of Guam and the Supreme Court of Guam to be used in judicial disqualification situations.


1. To view Guam’s new (2013) judicial disqualification forms click here.

2. For an article involving a recent (2013) recusal challenge made against a Guam Superior Court judge click here.

3. For a discussion of recusal and disqualification law in Guam and other U.S. Territories which is updated annually see Flamm, R., Judicial Disqualification: Recusal and Disqualification of Judges (Second Edition, 2007),
See also Van Dox v. Alcorn, 2008 Guam 7 at n.10 (Guam 2008), citing, R. Flamm, Judicial Disqualification. To locate libraries in Guam that have the current edition of this book click here