Rice v. Cayetano facts for kids

Quick facts for kids Rice v. Cayetano
Supreme Court of the United States
Argued October 6, 1999 Decided February 23, 2000
Full case name	Harold F. Rice, Petitioner v. Benjamin J. Cayetano, Governor of Hawaii
Citations	528 U.S. 495 (more) 120 S. Ct. 1044; 145 L. Ed. 2d 1007; 2000 U.S. LEXIS 1538; 68 U.S.L.W. 4138; 2000 Cal. Daily Op. Service 1341; 2000 Daily Journal DAR 1881; 2000 Colo. J. C.A.R. 898; 13 Fla. L. Weekly Fed. S 105
Prior history	Injunction denied, 941 F. Supp. 1529 (D. Haw. 1996); summary judgment granted for defendant, 963 F. Supp. 1547 (D. Haw. 1997); affirmed, 146 F.3d 1075 (9th Cir. 1998); cert. granted, 526 U.S. 1016 (1999).
Subsequent history	Remanded, 208 F.3d 1102 (9th Cir. 2000).
Holding
Hawaii's denial of the right to vote in OHA trustee elections based on ancestry violates the Fifteenth Amendment.
Court membership
Case opinions
Majority	Kennedy, joined by Rehnquist, O'Connor, Scalia, Thomas
Concurrence	Breyer (in result), joined by Souter
Dissent	Stevens, joined by Ginsburg (Part II)
Dissent	Ginsburg
Laws applied
U.S. Const. amend. XV

Rice v. Cayetano was an important case decided by the Supreme Court of the United States in 2000. The Court ruled that the state of Hawaii could not stop people from voting in elections for the Board of Trustees of the Office of Hawaiian Affairs (OHA) just because of their family background.

The case started in 1996. Harold "Freddy" Rice, a rancher from the Big Island, sued the state. John G. Roberts, who later became the Chief Justice of the United States, argued for Ben Cayetano, who was the governor of Hawaii at the time.

This ruling in Rice v. Cayetano had a big impact. It meant that people who were not of Native Hawaiian descent could vote in OHA elections. Later, another case, Arakaki v. State of Hawai‘i, built on this decision. It allowed non-Hawaiians to also run as candidates in OHA elections.

Understanding the Case: Background

Since 1978, Hawaii has held elections for the trustees of the Office of Hawaiian Affairs (OHA). The OHA is an agency that manages money and benefits for people called "Native Hawaiians" or "Hawaiians."

• Native Hawaiians are defined as descendants of at least half of the races living in the Hawaiian Islands before 1778.
• Hawaiians are descendants of the original people living in the islands in 1778.

By law, only these groups could vote for or be elected to the OHA Board of Trustees.

Why Harold Rice Sued

Harold F. Rice was a rancher whose family had lived in Hawaii since the mid-1800s. He was of European descent. In 1996, he tried to register to vote for the OHA trustees. The application asked if he was "Hawaiian" and wanted to vote in OHA elections. Rice crossed out "am also Hawaiian and" and checked "Yes."

Because he was not considered "Hawaiian" by the state's definition, his request to vote was denied. Rice then sued, saying this rule went against the 14th and 15th Amendments of the U.S. Constitution.

Early Court Decisions

The first court, the District Court for the State of Hawaii, ruled against Rice. They said that limiting who could vote for OHA trustees was not based on race. Instead, they saw it as recognizing the special status of Native Hawaiians. This was connected to Hawaii's duty to care for them. The court felt the OHA was not like a typical government office. It was focused on helping Hawaiians.

The next court, the 9th Circuit Court of Appeals, also denied Rice's claim. Rice argued that the voting rule was purely about race. The Court of Appeals agreed it might seem like a racial rule. However, they said that since Rice did not challenge the OHA's existence, which was based on a racial definition, they had to assume it was lawful. They believed the state could reasonably decide that Hawaiians, who were directly affected by the OHA, should choose its leaders. So, they saw the rule as political or legal, not just racial.

The Court of Appeals also compared the OHA election to a "special purpose election." They used a past case, Salyer Land Co. v. Tulare Water District (1973), as an example. In that case, only landowners could vote for leaders of a water district. The court had allowed this because those landowners were most affected by the district's decisions. The Court of Appeals said the OHA election was similar. It was for a "limited purpose" and the trustees did not have normal government powers. Since Hawaiians were most affected by the OHA, limiting the vote to them seemed fair.

Finally, the Court of Appeals noted that the voting rule was based on history. It was meant to help the Hawaiian people. They compared it to how Native American Indians receive "special treatment" in cases like Morton v. Mancari. In that case, the court said that special treatment for Native Americans was political, not racial. This was because it came from the government's unique duties to them.

Rice then took his case to the Supreme Court.

Hawaii's Unique History

To understand the arguments, it's important to know Hawaii's history:

• Independent Kingdom: Hawaii was an independent country from 1810 to 1893.
• Overthrow: In 1893, American businessmen and others overthrew Queen Lili'uokalani. They set up their own government.
• Annexation: In 1898, Hawaii became a U.S. Territory. About 1.8 million acres of land, once owned by the Hawaiian crown, were given to the United States.
• Land Use: The law stated that money from these lands should "be used solely for the benefit of the inhabitants of the Hawaiian Islands."
• Hawaiian Homes Commission Act (HHCA): In 1920, Congress passed the HHCA. It set aside 200,000 acres for Native Hawaiians to lease cheaply. A "Native Hawaiian" was defined as someone with at least half the blood of the races living in Hawaii before 1778 (the year Captain Cook arrived).
• Statehood and OHA: When Hawaii became a state in 1959, it agreed to keep the HHCA. In 1978, the state created the OHA. The OHA manages other lands for the benefit of Native Hawaiians.

Arguments Presented to the Supreme Court

Harold Rice's Argument

Harold Rice argued that the voting rule was a clear violation of the Constitution. He said that the original laws about Hawaii's public lands were meant to benefit all inhabitants, not just one race.

He also argued that the OHA elections were not "special purpose" elections like the water district case. He said the rule was clearly racial, not political. Rice believed that the special treatment given to Native American tribes in Morton v. Mancari did not apply to Native Hawaiians. He said there was no "special relationship" between the U.S. and Native Hawaiians like there was with Indian tribes.

Rice pointed out that Native Hawaiians became U.S. citizens when Hawaii became a territory. They were not treated like separate tribes. He argued that the OHA's use of a "blood quantum" (a certain amount of Hawaiian ancestry) to define who could vote was wrong.

Hawaii's Argument

The State of Hawaii disagreed. They argued that the voting rules were political, not racial. They said the OHA elections qualified as "limited purpose" elections.

Hawaii's main argument was about the "special relationship" between the U.S. and Native Hawaiians. They said that even though Native Hawaiians are not formally recognized as an Indian tribe, Congress has shown a special duty to them. They pointed to laws like the Hawaiian Homes Commission Act.

Hawaii also highlighted the 1993 "Apology Resolution" from Congress. This resolution apologized for the U.S. role in overthrowing the Hawaiian Kingdom. It recognized that Native Hawaiians had lost their right to self-determination. Hawaii argued that creating the OHA and its voting rules was simply upholding this "solemn trust obligation" to Native Hawaiians. They believed that Congress had the power to recognize this special status, and the courts should respect it.

The Supreme Court's Decision

The Supreme Court sided with Harold Rice. In a 7-2 decision, they ruled that Hawaii's voting rule violated the 15th Amendment. Justice Kennedy wrote the main opinion for the Court.

The Court stated that the 15th Amendment stops any attempt to limit voting based on family background, especially if that background is a stand-in for race. They said the OHA election rule was very clear: it gave the right to vote only to people of a specific ancestry. The Court found that "ancestry can be a proxy for race. It is that proxy here."

The Court also said that even if Congress had the power to treat Hawaiians like tribes, Congress could not allow a state to create a voting system based on race. The 15th Amendment is absolute. The OHA trustee election was a state election, and the Amendment clearly applied.

The Court rejected the idea that the rule was based on who benefited from the OHA, not race. They said that Hawaii's argument failed because it suggested that people of a certain race were more qualified to vote on certain matters. The Court said this idea went against the main meaning of the 15th Amendment.

Justice Kennedy ended the opinion by reminding Hawaii that the U.S. Constitution is "the heritage of all the citizens of Hawaii."

Justice Breyer's Agreement

Justice Breyer agreed with the Court's decision. He explained that the OHA did not seem enough like an Indian tribe to justify the special voting rules. He noted that the OHA's definition of a "Hawaiian" could include people with very little Hawaiian ancestry. He felt this went beyond any reasonable definition of a tribe.

The Dissents

Justice Stevens disagreed with the majority. He believed that two centuries of laws about Native Americans justified Hawaii's voting rules. He felt there was no unfair discrimination. He thought the "Apology Resolution" and other laws showed that Congress had a special duty to Native Hawaiians.

Justice Stevens argued that it was wrong to reject Hawaii's claims just because Native Hawaiians are not technically a "tribe." He saw a clear similarity between Native Americans and the people of the Hawaiian Islands. He also pointed out that in Morton v. Mancari, tribal membership was not the only factor. That case also allowed for preferences based on a certain amount of "Indian blood." He found it ironic that Native Hawaiians were being denied special benefits because they no longer had a native government, which he said history had taken from them.