From protecting the castle to the curtilage, a resident’s right to defend their home without the duty to retreat is now extended to include the surrounding curtilage such as their yard and driveway. 

After contentious debate, Senator Will Parkinson’s Bill 39 passed with near unanimous support– with just one senator opting out. 

Earlier this week, Governor Lou Leon Guerrero let it lapse into law but there's bound to be confusion, according to University of Guam legal studies faculty Frank Ishizaki. 

“I have this thought that between the legislature, the AG, and the police department, they really need to educate the community. Because otherwise we’re going to have to wait for a situation in which somebody is going to be judged. They took defensive action and it hurt somebody, whether the action was legally protected or not,” said Ishizaki. 

Throughout the years, Ishizaki served in several public safety leadership positions. 

He's calling for public education on what the Castle Doctrine Reform Act of 2024 fully entails. 

“What are your rights? When can you use force? Just because you piss me off is not a sufficient justification to hurt somebody,” Ishizaki said. 

“You have to have this reasonable fear of peril, death or serious injury…In legal terms, and especially law enforcement, it's an important term-- what is curtilage and what is not curtilage? We think of curtilage as an extended area outside your house that you take care of,” he added. 

He also made a clarification that this is not a ‘stand your ground’ law. 

“In our statute on basic self defense, you have a responsibility to try to retreat. If you're not able to retreat, then you can defend yourself. And ‘stand your ground’ means you don’t have to retreat,” he said. 

While there were several attempts to pass a controversial ‘stand your ground’ law in previous legislatures, it was met with public opposition. 

The Governor in her decision to not sign this castle doctrine measure noting it was passed without a public hearing.