  It has been claimed (Canup and Ward 2002; Ward 2003) that a long-lived
massive (compared to the mass of the Galilean satellites) circumplanetary gas
disk is inconsistent with Jupiter's low obliquity. Such a constraint could be
downplayed on the basis that it deals with a single observation. Here we argue
that this argument is flawed because it assumes a solar system much like that
of the present day with the one exception of a circumjovian disk which is then
allowed to dissipate on a long timescale (10^6-10^7 yrs). Given that the
sequence of events in solar-system history that fit known constraints is
non-unique, we choose for the sake of clarity of exposition the orbital
architecture framework of Tsiganis et al. (2005), in which Jupiter and Saturn
were once in closer, less inclined orbits than they are at present, and show
that Jupiter's low obliquity is consistent with the SEMM (solids-enhanced
minimum mass) satellite formation model of Mosqueira and Estrada (2003a,b).
