Rice v. Cayetano
528 U.S. 495 (2000)
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Rule of Law:
The Fifteenth Amendment prohibits a state from denying or abridging a citizen's right to vote in a statewide election on the basis of ancestry, as such a classification serves as a proxy for race.
Facts:
- In 1978, Hawaii amended its constitution to establish the Office of Hawaiian Affairs (OHA), a state agency tasked with bettering the conditions of 'native Hawaiians' and 'Hawaiians'.
- The Hawaiian Constitution and implementing statutes limit the right to vote for OHA's nine trustees to 'Hawaiians'.
- State law defines a 'Hawaiian' as any descendant of the aboriginal peoples who inhabited the Hawaiian Islands in 1778.
- Harold Rice, a citizen of Hawaii, is not a descendant of the peoples who inhabited Hawaii in 1778.
- In March 1996, Rice applied to register to vote in the OHA trustee elections.
- State officials denied Rice's application because he did not meet the required ancestral definition of a 'Hawaiian'.
Procedural Posture:
- Harold Rice sued Governor Benjamin Cayetano in the U.S. District Court for the District of Hawaii, alleging the voting restriction violated the Fourteenth and Fifteenth Amendments.
- The District Court granted summary judgment in favor of the State of Hawaii.
- Rice appealed the decision to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit affirmed the trial court's ruling, holding that the state could rationally conclude that the trust beneficiaries should be the ones to elect the trustees.
- The U.S. Supreme Court granted Rice's petition for a writ of certiorari.
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Issue:
Does Hawaii's constitutional provision, which restricts the right to vote for trustees of the state's Office of Hawaiian Affairs to 'Hawaiians' defined by their ancestry, violate the Fifteenth Amendment's prohibition against denying the right to vote on account of race?
Opinions:
Majority - Justice Kennedy
Yes. Hawaii's voting restriction is a race-based qualification that violates the Fifteenth Amendment's clear command against denying or abridging the right to vote on account of race. The State's definition of 'Hawaiian' as a descendant of those living on the islands in 1778 is not a race-neutral classification; ancestry here is a proxy for race. The court rejected the State's analogy to special treatment for Indian tribes under Morton v. Mancari, reasoning that OHA is an agency of the State, not a quasi-sovereign tribal entity, and its elections are state elections to which the Fifteenth Amendment squarely applies. The argument that the restriction aligns voters with trust beneficiaries also fails because race cannot be used to qualify some citizens and disqualify others from participating in the democratic process.
Concurring - Justice Breyer
Yes. While agreeing with the result, this opinion rejects Hawaii's justification for a different reason: the analogy to an Indian tribe is invalid on its face. First, OHA is not a true trust for native Hawaiians, as its funds come from various state sources and the underlying land trust benefits all people of Hawaii, not just one group. Second, the electorate for OHA is not analogous to a tribe because its definition—anyone with at least one ancestor in Hawaii in 1778—is unreasonably broad and unlike any actual tribal membership definition. This overbroad, state-created definition destroys the analogy to tribal self-governance, leaving the race-based voting scheme without a valid justification.
Dissenting - Justice Stevens
No. The voting restriction does not violate the Fifteenth Amendment because it is rationally tied to the unique trust relationship between the government and indigenous peoples, a relationship that includes native Hawaiians. Federal Indian law precedents, such as Morton v. Mancari, permit special treatment for indigenous groups based on their political, not racial, status. Congress has delegated this trust responsibility to Hawaii, and the OHA voting scheme rationally furthers the goal of self-governance for the trust's beneficiaries. The classification is based on ancestry tied to a specific political and cultural community, not on an invidious racial distinction, and thus does not fall under the Fifteenth Amendment's prohibition.
Dissenting - Justice Ginsburg
No. This opinion dissents for the reasons stated in Part II of Justice Stevens' dissent. Congress possesses the authority to create special trust relationships with indigenous peoples, including native Hawaiians, as recognized in Morton v. Mancari. The OHA and its voting system are rationally tied to fulfilling this federal trust obligation, which Congress delegated to the State of Hawaii. This relationship provides a valid basis for the voting provision under both the Fourteenth and Fifteenth Amendments.
Analysis:
This decision significantly reaffirms the broad scope of the Fifteenth Amendment, applying its prohibitions to any voting classification that uses ancestry as a proxy for race, even if the law is intended to be remedial. By distinguishing state-run elections from internal tribal governance, the Court limited the application of the 'political classification' exception from Morton v. Mancari, preventing states from creating race-based electorates for state agencies under the guise of indigenous self-governance. The ruling reinforces the principle that state elections must be open to all qualified citizens regardless of race or ancestry, leaving little room for states to carve out exceptions for special-purpose electoral bodies based on ethnic identity.
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