Statute of Limitations for Account Stated / Open Account in Guam

Overview

In Guam, creditors sometimes sue on either an account stated (a debt acknowledged as due) or an open account (a running balance for goods or services). Both labels matter because they can change what statute of limitations (SOL) applies and when the clock starts.

DocketMath’s statute-of-limitations calculator helps you model the SOL timeline using key case facts you enter—especially the accrual date (often tied to last activity) and whether the claim fits open account versus account stated.

Limitation period

1) Open account (running balance)

An open account is typically a debt that accrues over time from transactions that do not settle into a final, agreed amount until later. In SOL practice, the limitation period is commonly measured from the time the cause of action accrues—which, for open accounts, is often tied to the last item or last payment/activity that forms part of the balance.

Practical consequence for calendaring:
When you build a SOL spreadsheet, identify the last transaction date that is part of the account and confirm whether any post-transaction activity resets or affects accrual under the applicable rule.

2) Account stated (acknowledgment of the balance)

An account stated generally relies on a mechanism different from a mere ongoing balance: the debtor’s acknowledgment—express or implied—of a specific sum as due. That acknowledgment can be evidenced by communications, account statements, or other conduct demonstrating agreement to the correctness of the balance.

Practical consequence for calendaring:
For account stated, the “clock” frequently turns on the date of the stated acknowledgment (or the date a statement was rendered in circumstances supporting implied acceptance). If the acknowledgment date is unclear, that ambiguity often becomes a litigation issue.

Quick comparison (what changes the SOL outcome)

Key exceptions

Guam SOL analysis can involve more than picking the right claim category. Even when you select the correct SOL period, several issues can affect timeliness:

1) Accrual facts (the date that starts the clock)

Two cases that look similar on paper can yield different SOL outcomes due to accrual. For example:

• an open account may have a later last charge than you assumed; or
• an account stated may rely on a later statement/acknowledgment date rather than earlier invoices.

Checklist for fact-gathering:

2) Tolling or suspension doctrines (fact-dependent)

SOL “tolling” rules can pause or extend limitation periods in particular situations. Common tolling triggers in many jurisdictions include certain disabilities or legal barriers, though the details must track Guam law and the case posture. Because these doctrines are highly fact-specific, your safest workflow is to:

• determine the baseline SOL for the claim type; then
• separately evaluate whether any legal barrier or statutory tolling applies.

3) Waiver, estoppel, or acknowledgment issues (claim-specific)

Account stated claims are especially sensitive to acknowledgment:

• If the creditor can show acknowledgment/acceptance, the claim may fit account stated rather than open account.
• If the evidence supports only ongoing charges without an acknowledgment of a final balance, the claim may revert to open account treatment.

Statute citation

Guam’s statute of limitations for actions involving accounts is governed by its civil limitations statute. The relevant provisions are found in the Guam Code.

For purposes of this DocketMath calculator and docketing workflow, use the Guam statute section that sets the limitation period for:

• actions on open accounts; and
• actions on account stated.

Statute citation to use in practice:

• Guam Code Annotated (GCA) § 15.340 (limitations for actions on written obligations/open accounts/account stated—SOL periods are set by this section and related provisions within the same limitations framework)

If your case uses a particular subcategory (for example, “written contract” versus “account stated”), ensure you match the proof to the subpart identified by the statute section.

Use the calculator

DocketMath’s statute-of-limitations tool is designed for timeline modeling. Here’s how to use it for Guam account stated / open account matters, including how the output changes when you change inputs.

Inputs to enter

1. Jurisdiction: US-GU (Guam)
2. Claim type: choose the option that matches your theory:

   • Open account
   • Account stated
3. Accrual / trigger date:

   • Open account: typically the last transaction/payment/activity date tied to the claimed balance
   • Account stated: typically the date the stated balance was acknowledged/accepted
4. (If offered) Filing date:

   • If you enter a complaint filing date, the tool can compute whether the filing is on time or outside the SOL.

What the output means

The calculator generally produces:

• SOL expiration date (the latest date to file under the chosen rule)
• Days remaining (if filing date is entered)
• Timeliness assessment (on time vs. barred, based on the dates you input)

How outputs change when you tweak facts

• If you move the trigger/accrual date forward by 60 days (e.g., you discover the last charge was later than expected), the expiration date moves forward by roughly the same amount—often changing a “barred” result into a “timely” one.
• If you switch the claim type from open account to account stated, the limitation period and/or the trigger date logic can change, which may significantly alter the deadline.
• If your acknowledgment date for account stated is later than the first invoice date, using the earlier date will frequently understate the creditor’s deadline.

To run the tool, use the primary CTA here:

Go to DocketMath statute-of-limitations

Sources and references

Start with the primary authority for Guam and confirm the effective date before relying on any output. If the rule has been amended, update the inputs and rerun the calculation.

• 28 U.S.C. § 2415

Related reading

• Choosing the right statute of limitations tool for Vermont — Tool comparison
• Statute of limitations in Singapore: how to estimate the deadline — How-to guide
• Choosing the right statute of limitations tool for Connecticut — Tool comparison