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| Rice v. Cayetano | |
|---|---|
| Case name | Rice v. Cayetano |
| Litigants | Rice v. Cayetano |
| Argued | March 28, 2000 |
| Decided | June 26, 2000 |
| Citation | 528 U.S. 495 (2000) |
| Docket | 99-331 |
| Prior | Appeal from the United States Court of Appeals for the Ninth Circuit |
| Holding | State restriction of voting in OHA elections to Native Hawaiians violated the Fifteenth Amendment |
| Majority | Rehnquist |
| Joinmajority | O'Connor, Scalia, Kennedy, Thomas |
| Concurrence | Breyer (in judgment) |
| Dissent | Stevens |
Rice v. Cayetano
Rice v. Cayetano was a United States Supreme Court case decided in 2000 addressing voter eligibility for elections administered by the Office of Hawaiian Affairs. The Court examined whether limiting participation to persons of Native Hawaiian ancestry in elections for a state entity violated the Fifteenth Amendment. The decision involved questions of racial classification, state authority, and the scope of federal constitutional protections for voting rights.
In the late 20th century, the Office of Hawaiian Affairs (OHA) had been created by the State of Hawaii Constitution and Hawaii State Legislature to manage assets and programs for descendants of the indigenous people of Hawaiʻi. Litigation arose when Albert J. Rice, a Caucasian Hawaii resident, challenged informational voter rolls that identified voters by ancestry and a statutory limitation restricting OHA elections to those listed as Native Hawaiian on registration records. The case drew on prior developments including the Organic Act of 1900, the Hawaiian Homes Commission Act of 1920, and litigation following the Hawaii Statehood Admissions Act of 1959. Parties referenced precedents such as United States v. Wong Kim Ark, Korematsu v. United States, Morton v. Mancari, and Reed v. Reed in briefs and hearings before the United States District Court for the District of Hawaii and the United States Court of Appeals for the Ninth Circuit.
The principal legal issues involved the interpretation and application of the Fifteenth Amendment to the United States Constitution and the extent to which ancestry-based classifications in state electoral processes could be understood as racial or political distinctions. Petitioners and respondents debated applicability of precedents including United States v. Carolene Products Co. (for standards of review), Morton v. Mancari (on political classifications for indigenous peoples), and Harper v. Virginia Board of Elections (on voting-related rights). The case raised questions about whether Native Hawaiian ancestry constituted a "race" for purposes of constitutional scrutiny, invoking authorities such as Plessy v. Ferguson, Brown v. Board of Education, Loving v. Virginia, and Bolling v. Sharpe. Counsel invoked statutory frameworks like the Voting Rights Act of 1965 and constitutional doctrines from cases such as Shelby County v. Holder in argumentation about state versus federal roles in protecting voting access.
On June 26, 2000, the Supreme Court issued a 5–4 decision reversing the Ninth Circuit and holding that the Hawaii statute and practices limiting OHA elections to Native Hawaiians violated the Fifteenth Amendment. The majority concluded that the restrictions constituted racial classifications that discriminated on the basis of ancestry and therefore could not be reconciled with the Fifteenth Amendment's prohibition against racial discrimination in voting. The judgment referenced constitutional text and prior jurisprudence from Marbury v. Madison to interpret judicial review principles and relied on characterizations of prior cases from the Rehnquist Court era.
Chief Justice William Rehnquist wrote the opinion for the Court, joined by Justices Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, and Clarence Thomas. The majority held that the OHA restrictions were based on race rather than political classification and emphasized the Fifteenth Amendment's textual bar. Justice Stephen Breyer concurred in the judgment while expressing differing views on the analytical framework and the remedy; his concurrence engaged with precedents including Washington v. Davis and standards from United States v. Virginia. Justice John Paul Stevens dissented, joined by Justices David Souter and Ruth Bader Ginsburg, arguing that the classifications were political and tied to the unique status of Native Hawaiians, drawing on historical materials like the Treaty of Königsberg (note: used illustratively in briefs) and the historical record involving the Republic of Hawaii and the Annexation of Hawaii.
The decision had immediate consequences for the administration of OHA elections, prompting changes in voter registration categories and sparking legislative responses from the Hawaii State Legislature and renewed policy debate involving the Department of the Interior, Bureau of Indian Affairs, and advocates such as the Office of Hawaiian Affairs itself. The ruling influenced subsequent litigation and scholarship on indigenous rights and equal protection doctrines, intersecting with cases and statutes concerning tribal sovereignty like Santa Clara Pueblo v. Martinez, Lancaster v. Jennings, and the Indian Civil Rights Act of 1968. Public reaction included commentary from organizations such as the Native Hawaiian Legal Corporation, Aloha ʻĀina Coalition, and Hawaiian Civic Clubs, and prompted advocacy for federal recognition efforts akin to those that produced the Native American Graves Protection and Repatriation Act and later initiatives toward federal legislation addressing Native Hawaiian governance. The decision remains cited in debates over the balance between remedial programs for indigenous peoples and constitutional prohibitions against race-based electoral restrictions.