Rice v. Cayetano

Facts of the Case

In 1921, Congress enacted the Hawaiian Homes Commission Act (HHCA) with the purpose of rehabilitating the native Hawaiian population, which was defined to include any descendant of not less than one-half part of the blood of the races inhabiting the Hawaiian Islands previous to 1778. Upon Hawaii’s admission as a state in 1959, a federal statute granting Hawaii title to public lands provided that those lands–and the proceeds and income that the lands generated–were to be held as a public trust for various purposes, including the betterment of the conditions of native Hawaiians. In 1978, Hawaii established the Office of Hawaiian Affairs (OHA), a state agency that was to be (1) independent from other branches of state government