I began writing this Essay at the foot of the Ko‘olau Mountain Range on the windward side of the island of O‘ahu while on my summer break from teaching. That setting inspired, shaped, and guided the arguments in this Article.

Hawai‘i was once an independent and sovereign nation. The native inhabitants of the archipelago enjoyed an abundance of natural resources, which they consumed on a communal and subsistence basis, leaving ample time for the pursuit of social and cultural activities such as surfing and hula. After Hawaiians first interacted with Europeans in 1778, however, the native population began to fight disease, high infant mortality rates, and housing and healthcare inadequacies. Military personnel, missionaries, capitalists, and laborers recruited to work on sugar plantations migrated to the islands en masse, and by the end of the nineteenth century, the native population had been overwhelmed and substantially diminished. Then, in 1893, the U.S. military participated in the illegal overthrow of the Hawaiian Kingdom. The indigenous population continues to experience the ongoing harms of colonialization—today Native Hawaiians in Hawai‘i occupy the bottom rungs of the islands’ socioeconomic ladder.