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October 20, 2025
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To: Holeka Goro Inaba, Chair
Dennis "Fresh" Onishi, Vice Chair
Members of the Hawai'i County Council-25,
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Re: Res.320-25 Draft 01 2024-2026, Expresses Support for.Due Process and the o
Protection of Constitutional Rights for All Residents of the County of Hawai'i and Affirms
the County's Commitment to Multiculturalism and Its Immigrant Heritage, SUPPORT
25th Session: Wednesday, October 22, 2025, 9 a.m. Hilo Council Chambers, Rm. 1401
From: Elizabeth Jubin Fujiwara, Senior Partner
As a civil rights attorney since 1986 and, as importantly, a Volcano resident I offer this
analysis to assist our Council in further understanding the profound State constitutional
foundations that support this resolution. My testimony addresses how Resolution No.
320-25 aligns with, and advances core principles enshrined in our Hawai'i State
Constitution, statutory law, and our state's foundational values.
CONSTITUTIONAL ANALYSIS
I. Alignment with the Hawai'i Constitution's Foundational Principles
Resolution No. 320-25 stands firmly rooted in the constitutional bedrock of our state. The
Hawai'i Constitution's Preamble establishes our commitment to governance "with an
understanding and compassionate heart toward all the peoples of the earth."' This
foundational principle directly supports the resolution's affirmation of the County's
commitment to multiculturalism and protection of constitutional rights for all residents.
The resolution's request that the Mayor review existing, and potential agreements with
public and private partners to ensure constitutional rights of residents are protected
directly implements the constitutional mandate for compassionate governance toward all
peoples.
U. Due Process and Equal Protection Guarantees
The resolution's emphasis on due process protection finds explicit constitutional support
in Article I, Section 5 of the Hawai'i Constitution, which guarantees both due process and
equal protection." This provision requires that all persons within the state's jurisdiction
receive fair treatment under law, regardless of immigration status.
The resolution's specific request that the Hawai'i Police Department limit its involvement
with Immigration and Customs Enforcement to cases involving criminal activity serves as
a crucial safeguard ensuring that civil immigration violations do not become pretexts for
circumventing due process protections guaranteed to all residents. ' 1101
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Ref. To:
Ref. Date 0 T 2 2 2025
Telephone:(808)203-5436 0 Emaik ef@frlawhicom 0 `Weftite: www.fdaw6icom -
III. Cultural Preservation and Diversity Mandates
Article IX, Section 9 of the Hawaii Constitution explicitly grants the State power to
"preserve and develop the cultural, creative and traditional arts of its various ethnic
groups." Resolution No. 320-25's affirmation of the County's commitment to
multiculturalism and its immigrant heritage directly advances this constitutional mandate
by protecting the diverse communities that contribute to Hawai'i's rich cultural tapestry.
The resolution recognizes that protecting immigrant communities from excessive federal
enforcement actions preserves the cultural diversity that our Constitution explicitly values
and protects.
IV. The Law of the Splintered Paddle and Public Safety
Article IX, Section 10 enshrines the Law of the Splintered Paddle (mamala-hoe kanawai)
as "a unique and living symbol of the State's concern for public safety," decreeing that
"every elderly person, woman and child lie by the roadside in safety.""' This ancient law,
established by Kamehameha I in 1797, mandates protection for all vulnerable persons.
The Hawai'i Supreme Court has reaffirmed that this principle requires that "all people,
including the elderly, women and children, could lie by the pathways in safety" and that
"equality before the law has long been a guiding principle in Hawai'i."iv Resolution No.
320-25 advances this constitutional principle by ensuring that immigrant families,
including vulnerable elderly persons, women, and children, can access essential
services and interact with local government without fear of immigration enforcement
actions unrelated to criminal activity.
V. The Aloha Spirit Statute as Constitutional Guidance
The Aloha Spirit Statute (HRS §5-7.5) provides constitutional guidance for governmental
decision -making. The statute defines "Aloha Spirit" as "the coordination of mind and
heart within each person" and establishes that "each person must think and emote good
feelings to others." The statute specifically provides that those "using their power" in
government "may contemplate and reside with the life force and give consideration to the
'Aloha Spirit."'v
The Hawai'i Supreme Court has recognized that the Aloha Spirit law "establishes that
'aloha means mutual regard and affection in which each person is important to every
other person"' and that "these words define the shared vision for our state that we
adopted as a people."'
Resolution No. 320-25 embodies the Aloha Spirit by ensuring that all
residents —regardless of immigration status —are treated with the mutual regard and
affection that our constitutional framework demands.
LEGAL IMPLICATIONS AND PRECEDENTS
I. Historical Context and Constitutional Imperative
The constitutional importance of this resolution gains particular urgency when viewed
against Hawai'i's historical experience with discriminatory federal enforcement actions.
As documented "after the Empire of Japan attacked Pearl Harbor on December 7, 1941,
2
FDR ordered the internment of the Japanese Americans, regardless of their citizenship"
through Executive Order 9066""
The historical record shows that "these prisoners were never even charged with a crime,
let alone convicted. Two-thirds of them were U.S. citizens, born in the U.S." In Hawai'i
specifically, "the U.S. government interned 2,270 people of Japanese ancestry" with
"military personnel and local authorities collaborating on arrests."°"'
This historical precedent demonstrates the constitutional necessity of local governments
establishing clear boundaries regarding cooperation with federal enforcement actions
that may violate due process rights.
IL Contemporary Constitutional Concerns
Current federal immigration enforcement policies raise similar constitutional concerns.
Recent analysis warns that "America is now poised to allow a new version of the same
profound injustice" with plans to "begin rounding up as many as 20 million immigrants —
including U.S. citizens born here and granted birthright citizenship." ix
The Hawai'i Supreme Court has recently reaffirmed its commitment to constitutional
principles, stating: "We reject any suggestion that programs that seek to welcome all
people into our courtrooms, and support all members of our workforce, are in any way
inconsistent with our national and Hawai'i state civil rights laws. Rather, they protect
against bias, allow each individual to be judged on their merits, strengthen our
community, and enable us to live up to the promise of equal justice for all."x
III. Federal -State Constitutional Balance
Resolution No. 320-25 appropriately balances federal immigration enforcement authority
with state constitutional obligations. By limiting local cooperation to cases involving
criminal activity, the resolution maintains appropriate law enforcement cooperation while
protecting the due process and equal protection rights guaranteed by the Hawai'i
Constitution.
The resolution does not interfere with federal immigration enforcement authority but
rather ensures that local resources and authority are not used in ways that violate state
constitutional protections for residents.
REASONS for ADOPTION
Based on this constitutional analysis, I strongly recommend that the Council adopt
Resolution No. 320-25 for the following reasons:
1. Constitutional Compliance
The resolution directly implements multiple provisions of the Hawai'i Constitution,
including due process and equal protection guarantees, cultural preservation mandates,
and the Law of the Splintered Paddle's protection for vulnerable persons.
2. Historical Responsibility
Given HawaiTs experience with discriminatory federal enforcement actions during World
War II, the resolution represents a constitutional commitment to preventing similar
violations of residents' rights.
3
3. Community Safety and Trust
By ensuring that local law enforcement focuses on criminal activity rather than civil
immigration violations, the resolution promotes community safety by encouraging all
residents to cooperate with law enforcement and access essential services without fear.
4. Aloha Spirit Implementation
The resolution embodies the Aloha Spirit's mandate for mutual regard and affection
toward all persons, implementing this constitutional principle in practical governance.
5. Judicial Alignment
The resolution aligns with the Hawaii Supreme Court's recent reaffirmation of principles
supporting equal justice for all and rejection of discriminatory enforcement practices.
ADDRESSING POTENTIAL COUNTERARGUMENTS
Some may argue that immigration enforcement is exclusively a federal matter. However,
this resolution does not interfere with federal authority but rather ensures that local
government actions comply with state constitutional requirements. The Tenth
Amendment to the U.S. Constitution and principles of federalism support states' authority
to establish constitutional protections for their residents that exceed federal minimums.
Others may contend that limiting cooperation with federal immigration enforcement
compromises public safety. However, the resolution specifically maintains cooperation in
cases involving criminal activity while protecting the due process rights that enhance
community safety by encouraging all residents to report crimes and cooperate with law
enforcement.
CONCLUSION
Resolution No. 320-25 represents a constitutional imperative rooted in the foundational
principles of the Hawai'i Constitution. The resolution's protection of due process rights,
affirmation of multiculturalism, and limitation of immigration enforcement cooperation to
criminal matters directly implements constitutional mandates including due process and
equal protection guarantees, cultural preservation requirements, the Law of the
Splintered Paddle's protection for vulnerable persons, and the Aloha Spirit's call for
mutual regard and affection toward all people.
The resolution honors Hawai'i's constitutional commitment to governance "with an
understanding and compassionate heart toward all the peoples of the earth" while
learning from our historical experience with discriminatory federal enforcement actions.
I respectfully urge the Council to adopt Resolution No. 320-25 as a necessary
implementation of our state's constitutional principles and values. The resolution
strengthens our community by ensuring that all residents can access essential services,
cooperate with law enforcement, and contribute to our diverse cultural heritage without
fear of immigration enforcement actions unrelated to criminal activity.
Thank you for your consideration of this constitutional analysis and for your continued
commitment to protecting the rights and dignity of all Hawaii County residents.
Il
' PREAMBLE: "We, the people of Hawaii, grateful for Divine Guidance, and mindful of our Hawaiian heritage
and uniqueness as an island State, dedicate our efforts to fulfill the philosophy decreed by the Hawaii State motto,
'Ua mau ke ea o ka aina i ka pono.' We reserve the right to control our destiny, to nurture the integrity of our people
and culture, and to preserve the quality of life that we desire. We reaffirm our belief in a government of the people,
by the people and for the people, and with an understanding and compassionate heart toward all the peoples of the
earth, do hereby ordain and establish this constitution for the State of Hawaii."
" HRS Const. Art. I, § 5:
"No person shall be deprived of life, liberty or property without due process of law, nor be denied the equal
protection of the laws, nor be denied the enjoyment of the person's civil rights or be discriminated against in the
exercise thereof because of race, religion, sex or ancestry."
"'HRS Const. Art IX, § 10: "The law of the splintered paddle, mamala-hoe kanawai, decreed by Kamehameha I —
Let every elderly person, woman and child lie by the roadside in safety — shall be a unique and living symbol of the
State's concern for public safety.
"The State shall have the power to provide for the safety of the people from crimes against persons and
property."
'vStatement by the Hawaii Supreme Court Affirming Principles of Equal Justice for All (March 5, 2025):
"These principles of justice and servant leadership run deep in Hawaii. In 1797, King Kamehameha I decreed the
Law of the Splintered Paddle: Ke Kanawai Mamalahoe, that people great and humble should be respected alike, and
that all people, including the elderly, women and children, could lie by the pathways in safety. Equality before the
law has long been a guiding principle in Hawaii. It seeks to elevate all people by recognizing their common
humanity and eliminating the barriers that keep them from fully participating in society. It is a message that remains
as important today as it was in 1797, and will always continue to guide the work we do at the Hawai'i State
Judiciary."
v HRS § 5-7.5 --Aloha Spirit.
(a) "Aloha Spirit" is the coordination of mind and heart within each person. It brings each person to the self. Each
person must think and emote good feelings to others. In the contemplation and presence of the life force, "Aloha",
the following unuhi laula loa may be used:
"Akahai", meaning kindness to be expressed with tenderness;
"Lokahi", meaning unity, to be expressed with harmony;
"Oluolu", meaning agreeable, to be expressed with pleasantness;
"Haahaa', meaning humility, to be expressed with modesty;
"Ahmmi", meaning patience, to be expressed with perseverance.
These are traits of character that express the charm, warmth and sincerity of Hawai'i's people. It was the working
philosophy of native Hawai'ians and was presented as a gift to the people ofHawai'i. "Aloha" is more than a word
of greeting or farewell or a salutation. "Aloha" means mutual regard and affection and extends warmth in caring
with no obligation in return. "Aloha" is the essence of relationships in which each person is important to every other
person for collective existence. "Aloha" means to hear what is not said, to see what cannot be seen and to know the
unknowable.
(b) In exercising their power on behalf of the people and in fulfillment of their responsibilities, obligations and
service to the people, the legislature, governor, lieutenant governor, executive officers of each department, the'chief
justice, associate justices, and judges of the appellate, circuit, and district courts may contemplate and reside with
the life force and give consideration to the "Aloha Spirit".
v' Statement by the Hawaii Supreme Court Affirming Principles of Equal Justice for All (March 5, 2025):
"We strive to ensure that all people receive fair and respectful consideration in our court rooms. We are guided in
this work by the Aloha Spirit law, Hawai'i Revised Statutes § 5-7.5, which establishes that `aloha means mutual
regard and affection ...in which each person is important to every other person.' These words define the shared
vision for our state that we adopted as a people."
v'' After the Empire of Japan attacked Pearl Harbor on December 7, 1941, FDR ordered the internment of the
Japanese Americans, regardless of their citizenship two months later. Executive Order 9066. The War Relocation
Authority (WRA) was established on March 18ih to organize their removal. "These prisoners were never even
charged with a crime, let alone convicted. Two-thirds of them were U.S. citizens, born in the U.S.-the remainder
could not have become citizens because at that time people of Asian origin were prohibited from naturalization."
https://www.hawaiiintemment.orp-/untold-story/resources [Emphasis added]. See also Removed by Force: Tile
Eviction ofHawai`i's Japanese Americans Durine WWII [Removed by Force, directed by Ryan Kawamoto and
produced by Hawai'i attorney Bill Kaneko, is a full-length documentary which describes the untold story of 1,500
Americans of Japanese ancestry in Hawaii who were unlawfully evicted from their homes during WWII. These
cases were separate and apart from the unlawful incarceration of 120,000 Japanese American incarcerated on the
West Coast and Hawai'i. The film is based on the research and writings about the legal cases spearheaded by
the Honolulu JACL which resulted in $30M in redress compensation from the US Department of Justice];
Michi Weglyn's landmark Years of Infamy. The Untold Story of America's Concentration Camps, and the
NBC -produced documentary "Guilty by Reason of Race."
v"' Fueled by suspicions of disloyalty with military personnel and local authorities collaborating on arrests, the U.S.
government interned 2,270 people of Japanese ancestry in Hawaii. The "internees" were at first confined to the local
internment camps, with most being sent to O'ahu's U.S. Immigration station before being transferred to internment
camps on the mainland.
ix America is now poised to allow a new version of the same profound injustice that nearly destroyed the Japanese
in America. Donald Trump has vowed that he will move immediately to begin rounding up as many as 20 million
immigrants — including U.S. citizens born here and granted birthright citizenship - - and deport them. "If he
achieves his goal, approximately one in 16 people living in America could be imprisoned and deported over the next
four years. The time between President Roosevelfs executive order and the first arrival to the Manzanar War
Relocation Center was 30 days." A Racist Purge Almost Destroyed My Family. Another One Is Coming. Timothy
Soseki Kudo, hgps://www.nvtimes.com/2025/01/18/opinion/immigration-trump-ww2-Japanese- intemment.html
" Statement by the Hawaii Supreme Court Affirming Principles of Equal Justice for All (March 5, 2025).