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.
Venancio Roberto
Venancio Roberto was a resident of Hagåtña, Guam who briefly seized the office of Commissioner of Guam from December 31, 1898 to January 2, 1899 before his rule was declared illegitimate by Lieutenant Commander Vincendon Cottman of the USS "Brutus". In 1898, Roberto overthrew José Sisto, and was put in office by a military junta composed of a number of district leaders from around the island; only two days later, the United States Navy decided that Sisto held the legitimate claim to the office, despite Roberto's generally more pro-United States leanings. The coalition, which included local leader Father José Palomo y Torres and former governor Francisco Portusach Martínez, stepped aside until the ownership of Guam could be determined.