In the case of Carl T. C. Gutierrez and Madeleine Z. Bordallo v. Joseph F. Ada and Felix P. Camacho, 1999, the Supreme Court was asked to review a decision by Guam's highest court regarding its gubernatorial election in 1998 which declared Ada and Camacho as winners despite allegations of voting irregularities from Gutierrez and Bordallo who were incumbent governor and lieutenant governor respectively at that time. Gutierrez argued that there was an error in counting absentee ballots leading to his defeat but the local courts dismissed these claims stating they lacked merit after conducting recounts multiple times. The U.S Supreme Court declined to hear this appeal thereby upholding the lower court's ruling confirming Ada’s victory over Gutierrez for Governorship position on Guam island territory.

The dissenting opinion in the case of Carl T. C. Gutierrez and Madeleine Z. Bordallo v. Joseph F. Ada and Felix P. Camacho argued that the majority's decision was incorrect because it failed to properly interpret Guam law regarding election recounts, specifically Public Law 24-222 which states that a recount can only be requested within five days after an election certification is issued by the Guam Election Commission (GEC). The dissenting justices believed that this law should have been interpreted strictly, meaning that any request for a recount made after this period would not be valid regardless of circumstances or reasons provided for delay in filing such request; they also disagreed with the majority's interpretation of "good cause" as grounds for allowing late requests for recounts under certain conditions, arguing instead that "good cause" should only apply to situations where there are clear indications of fraud or misconduct during elections rather than mere allegations without substantial evidence supporting them.