Case Summary
**Case Summary: Doe v. Kamehameha Schools**
**Docket Number:** 7859013
**Court:** United States Court of Appeals for the Ninth Circuit
**Citation:** 470 F.3d 827 (9th Cir. 2006)
**Date Decided:** 2006
**Background:**
The case of Doe v. Kamehameha Schools revolves around the admissions policy of the Kamehameha Schools, which were established in Hawaii to provide education exclusively to native Hawaiian students. The schools were created under the will of Princess Bernice Pauahi Bishop, with the aim of improving educational opportunities for the Hawaiian people.
The controversy arose when a student, identified as Doe, applied for admission to Kamehameha Schools and was denied solely because he was not of Hawaiian ancestry. Doe challenged the admissions policy, arguing that it constituted racial discrimination and violated Title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving federal financial assistance.
**Legal Issues:**
The primary legal issues addressed in this case included:
1. Whether Kamehameha Schools’ admissions policy constituted unlawful racial discrimination under Title VI of the Civil Rights Act.
2. The extent to which Kamehameha Schools, as a private institution, could promote its mission of providing education specifically to native Hawaiians without contravening federal anti-discrimination laws.
**Court's Decision:**
The Ninth Circuit Court ruled in favor of Kamehameha Schools. The Court held that the admissions policy, while it may be viewed as racially exclusive, was permissible under the legal framework, considering the historical and cultural context surrounding the education of native Hawaiians. The Court reasoned that the schools were established with a clear intent to benefit native Hawaiians and remedy the effects of historical injustices faced by the Hawaiian community.
Furthermore, the Court emphasized that the policy was not a blanket prohibition against non-Hawaiians, as there were other educational opportunities available to them. The decision acknowledged the unique circumstances of Hawaii’s history and the intent behind the Kamehameha Schools’ founding.
**Conclusion:**
The Doe v. Kamehameha Schools case highlights the complexities of race, education, and affirmative action within the context of historical disenfranchisement. The ruling underscored the legal acknowledgment of indigenous rights and the balance between promoting educational opportunities for specific communities while navigating federal anti-discrimination laws. The case set a precedent for how similar institutions might operate in light of their missions to serve historically marginalized populations.