The government of the United States unincorporated territory of Guam, led by then-Governor Eddie Calvo, started campaigning in early 2011 for a plebiscite on Guam's future political status, with free association following the model of the Marshall Islands, Micronesia, and Palau as one of the possible options. The plebiscite, however, only allowed "native inhabitants" as defined under Guam law to register for it. A white, non-Chamorro resident, Arnold Davis, filed a federal lawsuit in 2011 for being denied registration for the plebiscite and a July 2019 ruling by the United States Court of Appeals for the Ninth Circuit ultimately blocked the plebiscite on the basis that the law was race-based and violated constitutionally protected voting rights; the United States Supreme Court declined to hear the Government of Guam's appeal in May 2020.