AI Disclosure Rules in the District of Guam

The District of Guam, based in Hagatna, serves one of the most geographically isolated federal courts in the United States. Guam sits in the western Pacific, roughly 6,000 miles from Washington, D.C., and handles a mix of federal criminal cases, military-related disputes, immigration matters, and civil litigation for an island population of about 170,000. Despite its small size, the District of Guam operates as a full Article III court within the 9th Circuit — and the AI compliance questions are the same as in any federal district.

AI Disclosure Rules in the District of Guam

The District of Guam has no AI disclosure rule. No local rule, no administrative order, no formal guidance. For a court this small — with a single active district judge and a magistrate judge — the absence of a specific AI rule is understandable. The March 2026 NYC Bar study found 41.7% of federal courts lack meaningful AI governance, and small territorial courts are disproportionately represented in that group.

The DGU sits within the 9th Circuit, the largest federal circuit and one of the more active on AI issues. The Northern District of California has multiple judges with AI standing orders. Hawaii's Judge Kobayashi adopted a standing order modeled on the Northern District of Texas prototype. The 9th Circuit's direction is toward more AI governance, even if its smallest courts have not yet acted.

The practical gap between Guam and the rest of the 9th Circuit is significant. AI policy discussions happening in San Francisco and Honolulu may not feel urgent on an island with a handful of federal practitioners. But the rules of federal practice are the same everywhere — Rule 11 does not have a small-court exception.

Individual Judge Standing Orders

No judges in the District of Guam have issued standing orders on AI use. With only one active district judge, the court's approach to AI will likely be shaped by that individual's perspective when the issue arises in a specific case.

The small bench means that a single order could instantly set the standard for all Guam federal practice. Practitioners should check the court website for updates and be prepared for the possibility that AI requirements could appear with little warning, potentially prompted by a specific case incident rather than a proactive policy decision.

Key AI Cases in DGU

No AI sanctions cases have emerged from the District of Guam. The landmark Mata v. Avianca case (SDNY) and the Couvrette sanctions ($109,700) provide the national precedent that applies to every federal court, including territorial courts.

Guam's docket includes cases where AI errors could be particularly problematic — federal criminal cases, military-related disputes, and matters involving Chamorro land rights and local territorial law. These areas involve specialized legal frameworks that AI tools, trained primarily on mainland U.S. law, may not handle accurately. A fabricated citation in a land rights case or a criminal sentencing memorandum would have immediate and serious consequences.

What Attorneys in DGU Should Do

**Check your judge's standing orders.** With one active district judge, this takes seconds. But it is an essential step that should be part of every filing routine.

**Disclose AI use even though it is not required.** In a court this small, transparency builds trust. A footnote noting AI assistance and independent verification demonstrates professionalism in a community where the bench and bar interact closely.

**Be extremely careful with Guam-specific law.** AI tools have very limited training data on Guam territorial statutes, Chamorro land rights, local court rules, and 9th Circuit decisions specific to Pacific territories. If you are citing territorial law, verify it directly through Guam government databases and local sources — not just through AI output.

**Verify all citations through primary sources.** This applies everywhere but is especially important in Guam, where the small volume of published decisions means AI tools have less data to draw from and are more likely to generate plausible-sounding but fictional citations to territorial court opinions.

**Maintain enterprise-grade tools.** Even if your practice is small, using professional legal research tools rather than consumer chatbots is critical. The cost of a Westlaw or LEXIS subscription is trivial compared to the cost of sanctions for a fabricated citation.

The Bottom Line

The District of Guam is small, remote, and has not adopted AI rules. But it is a fully functioning federal court within the 9th Circuit, and the standards for practice are identical to any mainland district. The small size of the court and bar actually increases the stakes — there is nowhere to hide an AI mistake when everyone in the courtroom knows each other.

Guam practitioners should watch the 9th Circuit's other courts for signals. When Hawaii and Northern California are already requiring AI disclosure, Guam is likely to follow eventually. Build the habits now.