Supreme Court of the United States

Rice v. Cayetano

February 23, 2000528 U.S. 495

Summary

The Court held that Hawaii's ancestry-based restriction on voting for Office of Hawaiian Affairs trustees violates the Fifteenth Amendment. Ancestry operated as a proxy for race, and neither federal Indian-law principles, special-purpose district precedents, nor the asserted alignment of trustees and trust beneficiaries justified racial restrictions in a state election. The Court left unresolved the validity of OHA's underlying programs and trusts and Congress's authority to treat native Hawaiians as Indian tribes. Justice Kennedy wrote for Chief Justice Rehnquist and Justices O'Connor, Scalia, and Thomas. Justice Breyer, joined by Justice Souter, concurred in the result because OHA's funding arrangements and broadly defined electorate did not sufficiently resemble a tribal trust and tribal membership; he rejected the majority's broader rationale. Justice Stevens dissented, with Justice Ginsburg joining Part II, arguing that federal responsibilities toward indigenous Hawaiians and delegated state authority justified the scheme and that its ancestry qualification was not forbidden racial discrimination. Justice Ginsburg separately dissented, concluding that the voting provision rationally furthered the delegated federal trust obligation.

Holding

  • Whether the ancestry qualification constitutes prohibited racial discrimination in voting.. Hawaii's restriction of voting in OHA trustee elections to descendants of the specified pre-1778 inhabitants violates the Fifteenth Amendment.
  • Whether federal Indian-law principles authorize the voting restriction.. Even assuming Congress could authorize Hawaii to treat Hawaiians or native Hawaiians as tribes, Congress could not authorize this race-based restriction in an election for state officials.
  • Whether special-purpose district voting precedents justify the restriction.. Exceptions to the Fourteenth Amendment's one-person, one-vote requirement do not excuse compliance with the Fifteenth Amendment's prohibition on racial voting qualifications.
  • Whether beneficiary status justifies limiting the OHA electorate.. The asserted alignment of trust beneficiaries and elected fiduciaries does not justify the race-based voting restriction.

Docket 98-818

Cited authorities

  • Haw. Rev. Stat. § 10-6
  • Haw. Rev. Stat. § 10-13.5
  • 42 U.S.C. §§ 2991-2992
  • Haw. Rev. Stat. § 10-2
  • 9 Stat. 977
  • 19 Stat. 625
  • 25 Stat. 1399
  • 30 Stat. 750

Cited by

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