Crawford v. Antonio B. Won Pat International Airport Authority, Guam

Plaintiff, individually and on behalf of others similarly situated, filed suit under 42 U.S.C. 1983 and Guam law, alleging procedural due process and equal protection violations in connection with plaintiff's attempts to be compensated for ancestral land taken by the government of Guam for the operation of A.B. Won Pat International Airport. As a preliminary matter, the Ninth Circuit held that the GIAA Defendants were not a proper party in this appeal and must be dismissed, because the GIAA was not named in either count that was at issue in this appeal.On the merits, the panel held that none of the Guam Public Laws raised by plaintiff, individually, read together, or read together with Chapter 80 of the Guam Code Annotated, gave rise to a protected property interest for purposes of a due process analysis. In regard to plaintiff's Fourteenth Amendment equal protection claims, the panel held that the classifications established in the Chapter 80 statutory scheme survived rational basis review. In this case, the Guam legislature's Chapter 80 statutory scheme focused on the additional issues presented by the claims of the In-Use Class and related rationally to legislative facts considered at the time to be true. View "Crawford v. Antonio B. Won Pat International Airport Authority, Guam" on Justia Law