United States v. Kaneholani

773 F. Supp. 1393, 1990 U.S. Dist. LEXIS 19272, 1990 WL 305440
CourtDistrict Court, D. Hawaii
DecidedDecember 11, 1990
DocketCrim. 89-00571 DAE
StatusPublished

This text of 773 F. Supp. 1393 (United States v. Kaneholani) is published on Counsel Stack Legal Research, covering District Court, D. Hawaii primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Kaneholani, 773 F. Supp. 1393, 1990 U.S. Dist. LEXIS 19272, 1990 WL 305440 (D. Haw. 1990).

Opinion

ORDER AFFIRMING MAGISTRATE’S DENIAL OF DEFENDANT’S MOTION TO DISMISS INFORMATION AND TO SUPPRESS EVIDENCE

DAVID A. EZRA, District Judge.

Defendant Daniel Peter Kaneholani (“Kaneholani”) appeals the magistrate’s denial of his pre-trial motions to dismiss the information and to suppress evidence. After denial of his pre-trial motions, Kaneholani pled guilty to violation of 16 U.S.C. § 1538(a)(1)(B) and (G) and 50 C.F.R. § 222.21 for taking and possessing parts of a Hawaiian monk seal. Kaneholani reserved his right to appeal the denial of his pretrial motions. He was sentenced to one year of incarceration and one year of supervised release.

Kaneholani appeals the magistrate’s denial of his motions on four grounds: (1) the Endangered Species Act (“Act”) does not prohibit the taking or possession of a Hawaiian monk seal by a native Hawaiian; (2) the Act’s exception for native Alaskans is a violation of equal protection; (3) the magistrate committed reversible error in failing to order the government to produce Jencks Act statements made by witness Gene Wit-ham (“Witham”); and (4) the magistrate committed reversible error by failing to require the government to produce Brady materials.

A. Standard of Review

After conviction, matters of law are reviewed de novo. United States v. Arrellando, 812 F.2d 1209 (9th Cir.1987); United States v. Miller, 771 F.2d 1219 (9th Cir.1985). The court reviews the constitutionality of statutes de novo. FTC v. American Nat’l Cellular, Inc., 810 F.2d 1511 (9th Cir.1987); Miller, 771 F.2d at 1225.

Jencks Act determinations are reviewed for an abuse of discretion. United States v. Moody, 778 F.2d 1380, 1383 (9th Cir.1985) (citations omitted). Failure to produce Jencks Act material does not require automatic reversal; instead, a harmless error test must be applied. United States v. Beasley, 576 F.2d 626, 629 (5th Cir.1978), cert. denied 440 U.S. 947, 99 S.Ct. 1426, 59 L.Ed.2d 636 (1979).

Since courts cannot “speculate whether [Jencks material] could have been utilized effectively” at trial, ... the harmless-error doctrine must be strictly applied in Jencks Act cases.

Goldberg v. United States, 425 U.S. 94, 111 n. 21, 96 S.Ct. 1338, 1348 n. 21, 47 L.Ed.2d 603 (1976) (citations omitted).

Nor does failure to produce Brady material require a new trial unless it can be shown that there was a reasonable possibility that the suppressed evidence would *1395 have materially affected the verdict. United States v. Lehman, 792 F.2d 899, 901 (9th Cir.1986); United States v. Dupuy, 760 F.2d 1492, 1501 n. 3 (9th Cir.1985). Such questions are reviewed de novo. Lehman, 792 F.2d at 901.

B. The Endangered Species Act Prohibits Kaneholani From Taking a Monk Seal

Title 16 U.S.C. § 1533(a)(1) authorizes the Secretary of the Interior to list species as either “endangered” or “threatened.” If a species is “endangered,” the Act prohibits “any person subject to the jurisdiction of the United States” from importing, exporting, taking, possessing, selling, offering for sale, delivering, carrying, transporting, or shipping such species. See 16 U.S.C. § 1538(a)(l)(AHF). Title 16 § 1540(b) provides criminal penalties for violations of the Act.

Kaneholani claims that he hunts monk seals for subsistence purposes and that therefore he, as a native Hawaiian, has an “aboriginal right” to continue this practice. He argues that there is a trust relationship between native Hawaiians and the federal government, and that based on this trust relationship, the federal government may not abrogate aboriginal rights absent “clear and plain” intent. Finally, Kaneholani argues that the Act does not express a “clear and plain” intent to abrogate these rights.

Kaneholani contends that because there is a legally recognized trust relationship between the federal government and American Indians, there should likewise be a trust relationship between the federal government and native Hawaiians. He cites Cherokee Nation v. Georgia, 30 U.S. (5 Pet.) 1, 17, 8 L.Ed. 25 (1831), in which Justice Marshall described American Indian tribes as “domestic dependent nations [whose] relation to the United States resembles that of a ward to his guardian.” Kaneholani suggests there is no reason to distinguish between American Indian tribes and native Hawaiians because “both groups saw their governments collapse and their lands taken away in the heyday of nineteenth century American imperialism.” Appellant’s Brief at 8.

Kaneholani also cites United States v. Dion, in which the United States Supreme Court recognized the right of the Yankton Sioux Tribe to shoot and hunt bald eagles but held that right had been abrogated by the Bald Eagle Protection Act. 476 U.S. 734, 106 S.Ct. 2216, 90 L.Ed.2d 767 (1985). Kaneholani attempts to draw a parallel between his own situation and that of the Yankton Sioux Tribe. He claims that he, like the Sioux, has an “aboriginal” right to hunt an endangered species, a right that can only be abrogated by the “clear and plain intent” of Congress.

Kaneholani’s argument lacks merit because he fails to recognize that the Yankton Sioux Tribe in Dion had a treaty right to hunt bald eagles. “[M]embers of the Yankton Sioux Tribe have a treaty right to hunt bald and golden eagles within the Yankton Reservation for noncommercial purposes.” 1 476 U.S. at 736, 106 S.Ct. at 2218-19. It was the conflict between this treaty right and the Bald Eagle Protection Act that the court addressed in Dion. Absent an explicit treaty or statutory right to take monk seals, Kaneholani can point to no legally recognized “aboriginal right” to take monk seals. 2

If Congress had intended to grant native Hawaiians an exception to the Act to permit the taking of monk seals, it would have passed a statute specifically granting this right. 3 This court has no power to fashion *1396 such a statute where none exists. Such action would be a violation of the separation of powers doctrine. “[T]he authority to.

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Cite This Page — Counsel Stack

Bluebook (online)
773 F. Supp. 1393, 1990 U.S. Dist. LEXIS 19272, 1990 WL 305440, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kaneholani-hid-1990.