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That day would never arrive. In 1898, five years after the haole-led coup d’état that ultimately brought about the Republic of Hawai‘i—a coup that even the United States president, Grover Cleveland, recognized as unlawful—Washington annexed the islands in the face of overwhelming opposition by the Hawaiian people.39 The annexation was clearly unconstitutional. Customary international law required land to be annexed through a treaty. This presented a problem for the United States, however, because its constitution mandated that treaties be ratified by a two-thirds majority vote in the Senate. Such a majority was not possible. Congress thus bypassed this constitutional requirement by passing a joint resolution in favor of annexation. (Resolutions require only a simple majority.) The failure to secure a treaty, argues J. Kehaulani Kauanui, rendered the entire enterprise illegal.40 Such legal shortcomings did not prevent the United States from working to consolidate its territorial land grab in the decades that followed, however. And as Hawai‘i became American, so, too, did surfing.

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