LGBT rights in Guam
Guam became the first overseas territory of the United States to recognize and perform same-sex marriages in June 2015. On June 5, 2015, Chief Judge Frances Tydingco-Gatewood of the United States District Court for the District of Guam ruled that Guam's prohibition on same-sex couples marrying is unconstitutional. She cited the Ninth Circuit Court of Appeals decision in "Latta v. Otter" striking down identical bans in Idaho and Nevada. The territory began issuing marriage licenses to same-sex couples four days later. The Legislature passed the "Guam Marriage Equality Act of 2015" on August 11, 2015, making Guam's marriage laws gender-neutral.
American imperialism
While territories such as Guam, the United States Virgin Islands, the Northern Mariana Islands, American Samoa and Puerto Rico remain under U.S. control, the U.S. allowed many of its overseas territories or occupations to gain independence after World War II. Examples include the Philippines (1946), the Panama canal zone (1979), Palau (1981), the Federated States of Micronesia (1986) and the Marshall Islands (1986). Most of them still have U.S. bases within their territories. In the case of Okinawa, which came under U.S. administration after the Battle of Okinawa during the Second World War, this happened despite local popular opinion. In 2003, a Department of Defense distribution found the United States had bases in over 36 countries worldwide.