
The District Court of Guam is a territorial court whose judges serve ten year terms. Judge Frances Tydingco-Gatewood, the sole judge on the court, had her term expire in August 2016. However, no nomination was put forward by the Trump Administration under November 30, 2020, with Judge Maria Teresa Cenzon’s nomination likely coming too late to be considered before the Biden Presidency.
Background
The daughter of Edward and Nita Cenzon from Pampanga Province, Cenzon was born in Guam.[1] Cenzon was a 1987 graduate of the Academy of Our Lady of Guam, after which she received a B.A. from Marquette University in 1992, and a J.D. from Loyola University Chicago School of Law in 1996. After graduating, Cenzon returned to Guam to start working at Barcinas & Terlaje, P.C. A year later, Cenzon became a Partner at Mair, Mair, Spade & Thompson, P.C.
In 2008, Cenzon moved to the firm of Cabot Mantanona, LLP, and then to Carlsmith Ball, LLP in 2009. In 2010, Cenzon became Director of Policy, Planning and Community Relations for the Unified Judiciary of Guam.
In 2011, Governor Eddie Baza Calvo appointed his Chief Counsel James L. Canto II to the Superior Court of Guam, and chose Cenzon to replace him. In 2012, Calvo named Cenzon to the Superior Court as well, where she has served since.
History of the Seat
The District Court of Guam has a single judgeship authorized. Judge Frances Tydingco-Gatewood, who was appointed by President Bush, saw her appointment expire in 2016. The Obama Administration did not make another appointment and Tydingco-Gatewood held the seat in the interim.
After taking office, the Trump Administration did not make a nomination to fill this seat until Cenzon was nominated on November 30, 2020, four weeks after the 2020 Presidential election.
Legal Experience
Prior to her appointment to the bench, Cenzon worked as General Counsel to Republican Governor Eddie Balza Calvo. In this role, Cenzon helped defend the Governor against a class action suit alleging that the Guam Government was illegally failing to pay taxpayers tax refunds.[2]
Before joining the Governor’s office, Cenzon spent a dozen years litigating in private practice. Among her notable cases during this time, Cenzon practiced before the Guam Supreme Court, defending the appointment of a visiting judge in a case where all the judges on the Superior Court were recused.[3]
Judicial Career
Cenzon has served on the Superior Court of Guam since 2012, where she has heard criminal, civil, and administrative cases. At the time of her appointment, Cenzon was the first Filipino-American on the judiciary of Guam.[4]
Overall Assessment
With her appointment having expired four years ago, Tydingco-Gatewood continues to serve on the Guam District Court due to the White House and the Senate’s failure to appoint a judge. Unfortunately, she will have to wait longer as Cenzon’s nomination likely comes too late to be considered before President Biden’s inauguration. While Cenzon has already made Guamanian history, her best hopes for appointment to the federal bench rest on a renomination by the Biden Administration.
[1] ABS-CBN News, Guam Gets First Fil-Am Judge, Dec. 28, 2012, ABS-CN News, https://news.abs-cbn.com/global-filipino/12/28/12/guam-gets-first-fil-am-judge.
[2] See Paeste v. Gov’t of Guam, 2012 U.S. Dist. LEXIS 100837 (D. Guam May 2, 2012).
[3] Lujan v. Lujan, 2000 Guam 21 (1999).
[4] See ABS-CBN News, supra n. 1.