Rice v. Cayetano

Background

Harold Rice, a Hawaii citizen, applied to vote in elections for the Office of Hawaiian Affairs (OHA) trustees but was denied because state law limits that vote to people who are "Hawaiians" as defined by descent from island residents in 1778. OHA is a state-created agency that manages funds and programs intended to benefit native Hawaiians and Hawaiians. Rice sued the State, arguing the ancestry-based voter restriction violated the Constitution.

Reasoning

The Court asked whether a state may limit voting to people with specified ancestral ties. The majority held that the OHA rule functions as a race-based voting qualification and therefore violates the Fifteenth Amendment. The opinion found ancestry was used as a proxy for race, pointed to statutory definitions that tracked race, and emphasized that OHA elections are state elections, not internal tribal affairs. The Court rejected defenses based on federal trust analogies and special-district cases and ruled for Rice.

Real world impact

The decision means Hawaii must allow previously excluded citizens to vote in OHA trustee elections and cannot use ancestry to bar voters in statewide elections. State lawmakers and agencies administering similar programs must revise election rules and voter registration practices. The ruling also limits the ability of states to draw voter qualifications tied to descent or ancestry.

Dissents or concurrances

Justice Breyer, joined by Justice Souter, agreed with the outcome but not the majority’s reasoning, suggesting a narrower analysis tied to the record. Justices Stevens and Ginsburg dissented, arguing Congress’ historic trust relationship with native Hawaiians supports Hawaii’s special voting rules.