Editing Duke Kahanamoku (section)

== ''Duncan v. Kahanamoku'' ==
{{Further|Duncan v. Kahanamoku}}
In 1946, Kahanamoku was the ''[[pro forma]]'' defendant in the landmark [[Supreme Court of the United States|Supreme Court]] case ''[[Duncan v. Kahanamoku]]''. While Kahanamoku was a [[military police]] officer during [[World War II]], he arrested Duncan, a civilian [[shipfitter]], for public intoxication.

At the time, Hawaii, not yet a state, was being administered by the United States under the [[Hawaiian Organic Act]]. This effectively instituted [[martial law]] on the island. After Duncan was tried by a military tribunal, he appealed to the Supreme Court. In a ''post hoc'' ruling, the court ruled that trial by military tribunal for the civilian was, in this case, [[unconstitutional]].<ref>''[https://supreme.justia.com/cases/federal/us/327/304/case.html Duncan v. Kahanamoku] {{Webarchive|url=https://web.archive.org/web/20180622060601/https://supreme.justia.com/cases/federal/us/327/304/case.html |date=June 22, 2018 }}'', 327 U.S. 304 (1946).</ref>