Rice v. Cayetano

Hawaii created the Office of Hawaiian Affairs (OHA) to manage lands and benefits for native Hawaiians, governed by trustees elected in statewide elections limited to citizens of Hawaiian ancestry (defined as descendants of the islands' 1778 inhabitants). Rice (plaintiff), a Hawaii citizen without Hawaiian ancestry, was barred from voting in OHA trustee elections and sued, arguing the restriction violated the Fifteenth Amendment; the state argued the arrangement was comparable to the special treatment Congress affords Indian tribes. Lower courts sided with the state, and the U.S. Supreme Court granted certiorari.