Duke Kahanamoku - Duncan V. Kahanamoku

Kahanamoku was the pro forma defendant in the landmark Supreme Court case Duncan v. Kahanamoku. While Kahanamoku was a military police officer during World War II, he arrested Duncan for public intoxication. At the time, Hawaii, not yet a state, was being administered under the Hawaiian Organic Act which effectively instituted martial law on the island. Duncan was therefore tried by a military tribunal and appealed to the Supreme Court. In a post hoc ruling, the court ruled that trial by military tribunal was, in this case, unconstitutional.