In the 1999 case of Harold F. Rice v. Benjamin J. Cayetano, Governor of Hawaii, the U.S Supreme Court ruled that a Hawaiian law allowing only people with Native Hawaiian ancestry to vote in elections for Office of Hawaiian Affairs (OHA) was unconstitutional as it violated the Fifteenth Amendment's prohibition against voting qualifications based on race. The plaintiff, Harold F.Rice, a non-Native resident of Hawaii challenged this law arguing that he was being denied his right to vote because he did not have native bloodline which amounted to racial discrimination under federal laws including Voting Rights Act and Fourteenth and Fifteen Amendments. In a 7-2 decision led by Justice Anthony Kennedy, the court held that using racial distinctions as basis for voting rights is discriminatory and violates constitutionally protected equal protection principles.

In the dissenting opinion for Harold F. Rice v. Benjamin J. Cayetano, Justice Stevens argued that Hawaii's voting restriction to only those of Hawaiian descent for Office of Hawaiian Affairs (OHA) trustees was not a racial classification but rather a political one, similar to restrictions on tribal elections in Native American communities. He contended that the majority misinterpreted the 15th Amendment and failed to recognize Hawaii's unique history and its trust relationship with native Hawaiians established by Congress when it admitted Hawaii as a state. The OHA election system was designed specifically to address issues related directly to this group due their historical disadvantages and special needs; thus, limiting voters in these elections did not violate equal protection principles because it served legitimate purposes tied closely with responsibilities assumed by State under Admission Act.