The Fate of the Native Hawaiians: The Special Relationship Doctrine, the Problem of Strict Scrutiny, and Other Issues Raised by Rice v. Cayetano

Harold "Freddy" Rice is a Native Hawaiian in the sense that he was born in the Hawaiian Islands and can "trace[ ] his ancestry to two members of the legislature of the Kingdom of Hawaii, prior to the Revolution of 1893. " He is a taxpayer and a qualified elector of the United States, the State of Hawaii, and the County of Hawaii. When Rice applied to vote in the 1996 election for the trustees of the Office of Hawaiian Affairs ("OHA"), however, his application was denied. Why?

Because, according to a state statute, he was not Hawaiian enough.