American Occupation of the Hawaiian State:
A Century Gone Unchecked
David Keanu Sai
PhD candidate, Political Science
University of Hawai’i at Manoa

Hawaiian Journal of Law and Politics (Vol. 1, Summer 2004)

page 66

In 1988, Kmiec, acting Assistant Attorney General, Office of Legal Counsel for the Department of Justice, raised questions about Congress’s authority to annex the Hawaiian Islands by municipal legislation. He concluded that it was “unclear which constitutional power Congress exercised when it acquired Hawaii by joint resolution.”

From: Douglas Kmiec, “Legal Issues Raised by Proposed Presidential Proclamation To
Extend the Territorial Sea,” Opinions of the Office of Legal Counsel of the U.S.
Department of Justice 12 (1988): 262.