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====Background==== Several memoirs, reports, and unofficial documents in the decades since World War II have stated Palmyra was placed under naval jurisdiction in 1934 as part of [[Executive order (United States)|Executive Order]] 6935.<ref>{{cite web| title=Executive Order 6935 |url=https://en.wikisource.org/wiki/Executive_Order_6935|publisher=U.S. Government |date=December 29, 1934}}</ref> However, Palmyra is not mentioned in this order in any capacity. The first official mention of Palmyra under Naval Jurisdiction comes from a 1939 letter from the [[Homer Stille Cummings|U.S. Attorney General]], mentioned in a 1997 Insular Areas report, concluding "Palmyra was U.S. public land and that the Fullard-Leo claim was invalid. S. Rep. No. 83-886 at 37."<ref>{{cite web |title=US Insular Areas Report |url=http://palmyraarchive.org/items/show/144 |publisher=U.S. Government |date=November 1, 1997 |access-date=August 21, 2017 |archive-url=https://web.archive.org/web/20170821090629/http://palmyraarchive.org/items/show/144 |archive-date=August 21, 2017 |url-status=dead }}</ref> Soon after this determination, [[Franklin D. Roosevelt|President Roosevelt]] issued [[Executive Order]] 8616, officially, "Placing Palmyra Island, Territory of Hawaii, Under the Control and Jurisdiction of the Secretary of the Navy".<ref>{{cite web |title=Executive Order 8616 |url=http://palmyraarchive.org/items/show/139 |publisher=U.S. Government |date=December 19, 1940 |access-date=August 21, 2017 |archive-url=https://web.archive.org/web/20170821084422/http://palmyraarchive.org/items/show/139 |archive-date=August 21, 2017 |url-status=dead }}</ref> Starting in 1937, the Fullard-Leo family began attempts to lease Palmyra to the U.S. Navy. During negotiations, the government filed a [[quiet title]] action against the Fullard-Leos and [[Henry Ernest Cooper]]'s six surviving children, claiming property at Palmyra had never been privately owned under the Kingdom of Hawaii or later. The case reached the U.S. Supreme Court. The Insular Areas report states, "While the suit was pending during World War II, the Navy occupied Palmyra and built a runway and several buildings." The Fullard-Leos and Coopers finally won their case in ''United States v. Fullard-Leo et al.'', 331 U.S. 256 (1947), which quieted good land title against the federal government in favor of private landowners. The opinion acknowledged certain of Henry Maui's and Joseph Clarke's interests (331 U.S. 256 at 278) but their heirs and their successor Mrs. Bella Jones were not made parties to the case.<ref>{{cite web|title = GAO/OGC-98-5 β U.S. Insular Areas: Application of the U.S. Constitution | date = November 7, 1997|url= http://www.gpo.gov/fdsys/pkg/GAOREPORTS-OGC-98-5/content-detail.html|publisher= U.S. Government Printing Office |access-date=March 23, 2013}}</ref> {{As of|2007}}, descendants of Henry Cooper still owned two small Home islets in the southwestern tip that were not sold in 1922.<ref name="DOI OIA"/> In July 1938, [[United States Secretary of the Interior|Secretary of the Interior]] [[Harold L. Ickes]] wrote a letter to [[Franklin D. Roosevelt|President Roosevelt]], imploring him not to turn Palmyra over to the U.S. Navy for use as a military base. Quoting his letter, he writes, <blockquote>... the Navy Department has plans for the acquisition and development of the island as an air base. Our representatives have studied conditions at Palmyra and other islands in the south Pacific, and they report that use of this small land area as an air base for Navy Department purposes would undoubtedly destroy much, if not all, that makes the island one of our most scientifically and scenically unique possessions.</blockquote> The letter was unsuccessful, and plans for the base proceeded.<ref>{{cite web |url=http://palmyraarchive.org/items/show/192 |title=MEMORANDUM FOR THE PRESIDENT REGARDING PALMYRA ISLAND |last1=Ickes |first1=Harold |date=July 11, 1938 |publisher=Office of the Secretary of the Interior |access-date=December 9, 2017 |archive-url=https://web.archive.org/web/20171209152158/http://palmyraarchive.org/items/show/192 |archive-date=December 9, 2017 |url-status=dead }}</ref> On February 14, 1941, Roosevelt issued Executive Order 8682 to create naval defenses areas in the central Pacific territories. The proclamation established the "Palmyra Island Naval Defensive Sea Area", encompassing the territorial waters between the extreme high-water marks and the three-mile marine boundaries surrounding the atoll. "Palmyra Island Naval Airspace Reservation" was also established to restrict access to airspace in the area. Only U.S. government ships and aircraft were permitted to enter the naval defense areas at Palmyra Atoll unless authorized by the [[United States Secretary of the Navy|Secretary of the Navy]]. The Navy took over the atoll for use as the [[Palmyra Atoll Airfield|Palmyra Island Naval Air Station]] on August 15, 1941. From November 1939 through 1947, the atoll had resident federal government representatives and island commanders. The atoll was [[Shelling of Johnston and Palmyra|shelled by a Japanese submarine]] in 1941, with no significant damage or injuries. The government made extensive alterations to the landforms. It blasted and dredged a ship channel from the open sea into the West Lagoon, which had been completely enclosed by islands and reefs and was non-navigable until the channel reached the lagoon on May 15, 1941. It joined islands with causeway roads, built new islands, and extended existing islands with dredged coral spoil, including the main runway on Cooper Island, an emergency landing strip called Sand Island joined by a causeway to Home Island and two artificial runway islands that were not completed. These alterations blocked the water flow through the atoll and are believed to have severely harmed the natural ecology of the lagoons.<ref>{{cite journal |title=Shoreline Changes and Sediment Redistribution at Palmyra Atoll (Equatorial Pacific Ocean): 1874βPresent |last1=Collen |first1=J. D. |last2=Garton |first2=D. W. |last3=Gardner |first3=J. P. A. |date=2000 |journal=Journal of Coastal Research |volume=25 |issue=3 |pages=711β722 |doi=10.2112/08-1007.1 |s2cid=129960273 }}</ref>
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