Rice v. Cayetano

Rice v. Cayetano was a landmark decision by the Supreme Court of the United States that struck down a Hawaiian election law as unconstitutional. The statute had limited voting for trustees of the Office of Hawaiian Affairs to persons of Native Hawaiian descent. The Court, in an opinion by Justice Anthony Kennedy, held that this race-based voting restriction violated the Fifteenth Amendment.

Background and legal context

The case originated from a challenge by Harold F. Rice, a Hawaii Island rancher of European ancestry, who was prohibited from voting in an Office of Hawaiian Affairs trustee election. The Office of Hawaiian Affairs was established by the Hawaii State Constitution to manage resources and programs for the benefit of Native Hawaiians. The disputed law, rooted in amendments to the Hawaii State Constitution and the Hawaiian Homes Commission Act, defined the electorate as "Hawaiian," meaning any descendant of the aboriginal peoples prior to Captain James Cook's arrival in 1778. Rice argued this racial classification was impermissible under the United States Constitution. The United States Court of Appeals for the Ninth Circuit had upheld the law, prompting an appeal to the Supreme Court of the United States.

Supreme Court decision

In a 7-2 decision delivered on February 23, 2000, the Court ruled in favor of Rice. Justice Anthony Kennedy's majority opinion concluded that the state's voting qualification was a clear racial classification, explicitly prohibited by the Fifteenth Amendment. The Court rejected the argument that the classification was political rather than racial, noting the state's definition relied solely on ancestry as a proxy for race. The opinion also dismissed parallels to the unique political relationship between the federal government and Native American tribes, as recognized in cases like Morton v. Mancari. Justices John Paul Stevens and Ruth Bader Ginsburg filed dissenting opinions, with Stevens arguing the law represented a permissible political recognition of the indigenous people of Hawaii.

Implications and aftermath

The decision had immediate and profound consequences for Hawaiian law and politics. It invalidated the electoral scheme for the Office of Hawaiian Affairs, forcing the Hawaii State Legislature to open subsequent trustee elections to all registered voters in Hawaii. The ruling also cast significant doubt on the constitutionality of other programs and institutions predicated on Native Hawaiian ancestry, influencing subsequent legal challenges such as Arakaki v. Hawaii. It energized political movements advocating for federal recognition of Native Hawaiians, similar to the status of Native American tribes. The decision remains a pivotal reference in debates over race, sovereignty, and the legal status of Native Hawaiians within the United States.

See also

* Fifteenth Amendment to the United States Constitution * Office of Hawaiian Affairs * Native Hawaiian * Morton v. Mancari * Arakaki v. Hawaii * Hawaiian sovereignty movement

Category:United States Supreme Court cases Category:United States voting rights case law Category:Hawaii law Category:2000 in United States case law