A short one from the Supreme Court of Guam (long opinion, but short post), which reversed a trial court ruling that awarded title to the land beneath a wastewater treatment plant to a private owner, holding that the property was never conveyed out of public ownership and remains with the Guam Waterworks Authority.
The opinion in Gov’t of Guam v. Core Tech Int’l Corp., No CVA24-007 (Guam, Aug. 2, 2026), is mostly about “dirt law” stuff, like the effect of Torrens title registration, the after-acquired title doctrine, and ancestral land claims. But there’s also a kernel of inverse condemnation goodness making this one worth a read.
The disputed property is beneath the Northern District Wastewater Treatment Plant, a facility constructed while the land was owned by the federal government as part of Andersen Air Force Base. Thirty years ago, Guam transferred its water and wastewater assets to GWA, which purported to convey, among many other assets, the treatment plant property “in fee simple absolute.” In 2002, the feds returned a large tract of former military property to the Territory, which, in turn, conveyed some of that land to the Guam Ancestral Lands Commission, which later transferred portions of that land to the heirs of former owners. Through a series of subsequent transactions, title eventually landed in the hands of Core Tech International.
The trial court concluded that although GWA initially obtained title through the 1997 deed, that title automatically reverted to the Territory when GWA failed to complete certain required survey maps, after which title then passed through mesne conveyances and ultimately vested in Core Tech.
The Supreme Court disagreed, however, concluding instead that the 1997 grant deed from the Territory to GWA unambiguously conveyed the treatment plant property in fee simple, and nothing that occurred later (or didn’t occur) altered that. In short, the reversion from GWA to the Territory was the critical piece in Core Tech’s claim to ownership … but the reversion never happened.
Of note to your dirt lawyer types, the opinion reiterates a basic principle frequently lost in Torrens disputes: registration provides powerful protection, but it is not absolute. The court emphasized that the Torrens system of registration protects bona fide purchasers acting in good faith, but the record contained evidence suggesting Core Tech and its predecessors were aware of the wastewater plant’s existence and of the competing public claims. Among other things, title documents referenced the sewer treatment plant, and survey materials identified the parcel as not returned to ancestral landowners.
All was not lost, however. Although it held that GWA owns the property and quieted title in its favor, the court also concluded that Core Tech’s takings/inverse condemnation claims survived. The court made clear that ownership and compensation are distinct issues, and resolving title in favor of the government does not necessarily foreclose claims for compensation arising out of the complicated history of condemnation, land-return programs, and utility occupation. As best we can figure it, the inverse condemnation claim was an alternative theory for Core Tech: we own the property, but if it is determined we don’t, then you took it from us without compensation.
Gov’t of Guam v. Core Tech Int’l Corp., No CVA24-007 (Guam, Aug. 2, 2026)