Guam § 31 - Soliciting to Submit to Operation, Etc., to Cause an
Full text of Guam Guam Code Annotated § 31 — Soliciting to Submit to Operation, Etc., to Cause an, with citation guidance and answers to common questions.
§ 31. Soliciting to Submit to Operation, Etc., to Cause an
Abortion. Every person who solicits any woman to submit to any
operation, or to the use of any means whatever, to cause an abortion
as defined in § 31.20 of this Title is guilty of a misdemeanor.
In Guam Society of Obstetricians & Gynecologists v. Ada, 962 F.2d 1366
(9th Cir 1992), cert. denied, 506 U.S. 1011 (1992), the Ninth Circuit Court
invalidated these provisions, relying on Roe v. Wade, 410 U.S. 113 (1972),
and also permanently enjoined enforcement of P.L. 20-134. Roe v. Wade
was overturned by Dobbs v. Jackson Women’s Health Organization, 597
U.S. -- (2022), and in response to a request from members of the 36th
Guam Legislature, the Attorney General of Guam issued Opinion
COL7/19/2022
Memorandum LEG-22-0324, finding that the 20th Guam Legislature had
exceeded its Organic Act authority in enacting P.L. 20-134, and that P.L.
20-134 was void ab initio. See Att’y. Gen. Op. Mem LEG-22-034 (July 6,
2022). Based on this guidance, the provisions of P.L. 20-134 will not be
codified in the GCA.
Source: official Guam text · Last verified 2026-08-27
Frequently Asked Questions About Guam § 31
What does Guam Code Annotated § 31 cover?
Section 31 ("Soliciting to Submit to Operation, Etc., to Cause an") is part of the Guam Code Annotated, the codified statutory law of Guam. It sets out the legal rule or procedure described in the text above. Statutes are amended regularly, so always verify against the official source.
How do I cite Guam § 31?
A common citation format is "Guam Code Annotated § 31" (Guam). Legal writing may require the code abbreviation, section number, and year or edition. Match the style required by your court, professor, or publisher.
Is this the official text of Guam law?
No. This page is for research and education and may not include the most recent amendments. For official current law, check the Guam official source linked on this page or consult a licensed Guam attorney.
How does Guam § 31 apply to my situation?
Statutes are interpreted in context, and application depends on your specific facts. Only a licensed attorney in Guam can advise on how this section applies to you. Contact your state or local bar association for a referral.
Sources & Verification
Not legal advice. Verify against the official source and consult a licensed attorney in Guam.