People of Guam v. Vincent T. Tedtaotao

Summary

The Supreme Court of Guam reversed the Superior Court's summary denial of Vincent Tedtaotao's post-conviction motion challenging the mandatory life-without-parole sentence imposed for a 1985 aggravated murder committed when he was nineteen. Because Tedtaotao's claim was indistinguishable from the colorable claim this court recognized in Adriatico, he was entitled to an evidentiary hearing on evolving brain-development science and to have his illegal-sentence claim evaluated under the modified 'evolving standards of decency' test incorporating objective indicia of Guam's societal values. The court declined to reach Tedtaotao's inadequately briefed claim that the courts possess inherent authority to grant compassionate release, observing that any such authority must rest on positive law. No separate opinions were filed.