Home › Case briefs › Constitutional Law

Rice v. Cayetano

Supreme Court of the United States · 2000 · Constitutional Law

Constitutional LawFifteenth AmendmentVoting RightsRace ClassificationsFifteenth Amendmentvoting qualificationsancestryrace proxy

Facts

Hawaii limited voting for trustees of the Office of Hawaiian Affairs, a state agency, to persons classified by statute as "Hawaiians," meaning descendants of the aboriginal peoples inhabiting the Hawaiian Islands in 1778. OHA is a state agency created by the Hawaii Constitution and charged with administering programs and funds for the benefit of "native Hawaiians" and "Hawaiians." Harold Rice was a citizen of Hawaii and a descendant of preannexation residents of the islands, but he was not descended from pre-1778 inhabitants and therefore could not register to vote in OHA trustee elections. The election for OHA trustees was conducted on a statewide basis.

Issue

Whether Hawaii may restrict voting in statewide elections for trustees of a state agency to persons who are descendants of the aboriginal peoples inhabiting Hawaii in 1778. More specifically, whether that ancestry-based voting qualification violates the Fifteenth Amendment's prohibition on denying or abridging the right to vote on account of race.

Rule

The Fifteenth Amendment prohibits any state voting qualification that denies or abridges the right to vote on account of race. A State may not evade that command by using ancestry as a proxy for race; when ancestry is used as a racial definition and for a racial purpose in a state election, the restriction is unconstitutional.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nevada creates the Desert Heritage Authority, a state agency that manages public land revenues and cultural programs. Trustees are elected statewide, but only citizens descended from persons who belonged to the indigenous peoples living in the region in 1800 may vote.

A Reno resident excluded from the election challenges the restriction under the Fifteenth Amendment. What is the strongest argument for invalidating the voting rule?

Explanation. The controlling rule is that a State may not deny or abridge the right to vote on account of race, and it cannot evade that command by substituting ancestry for race when ancestry functions as a racial definition. Because the trustees are elected in a statewide election for a state agency, the Fifteenth Amendment applies in full. The absence of the word "race" is not enough to save the law.