Hawai'i v. Office of Hawaiian Affairs

Under the 1959 Admission Act, the United States granted Hawaii (plaintiff) title to public lands to be held in trust for Native Hawaiians. In 1993, Congress passed a resolution apologizing for the historical overthrow of the Kingdom of Hawaii, expressly stating it was not meant to settle any claims against the United States. When Hawaii sought to sell a parcel of trust land, the Leiali'i parcel, to its housing finance agency, the Office of Hawaiian Affairs (defendant) demanded that the sale acknowledge potential Native Hawaiian claims to the land under the apology resolution; Hawaii's supreme court ultimately agreed Hawaii had to consider such claims before selling.