Guano Islands Act in 1856. Under its terms, whenever a U.S. citizen discovered guano on an unclaimed, uninhabited island, that island would, “at the discretion of the President, be considered as appertaining to the United States.” It was an obscure word, appertaining, as if the law’s writers were mumbling their way through the important bit. But the point was this: those islands would, in some way, belong to the country.