When the Territory of Hawaii was incorporated on April 30, 1900, Palmyra Atoll was incorporated as part of that territory. However, when the State of Hawaii was admitted to the Union in 1959, the Act of Congress explicitly separated Palmyra Atoll from the newly federated state. Why?

The answer to this lies within the records of the Senate Committee on Insular and Interior Affairs during the 83rd Congress of the United States.

Palmyra was officially annexed by the Kingdom of Hawaii in an 1862 mission commissioned by Kamehameha IV, and with that in mind, Palmyra was one of the islands specifically included in the Joint Resolution of Congress passed on July 7, 1898. That resolution proclaimed the Republic of Hawaii as part of the United States, and arguments still continue about whether or not the resolution was legal.

Now, there's a complicated chain of title for Palmyra that ends up leaving Henry Ernest Cooper Sr. of Honolulu with two-thirds ownership in 1911 after the Pacific Navigation Company transferred it to him. The custody of the title to the remaining third is even more complicated and involves probate courts and all that kind of fun stuff that you probably don't care about.

In any event, the U.S. Supreme Court determined in United States v. Fullard-Leo (1947) that Palmyra was a part of the United States and part of the Territory of Hawaii.

This is where things get political.

Last year, Williamson Chang, a professor at the University of Hawaii-Manoa wrote a paper called "Darkness over Hawaii: The Annexation Myth is the Greatest Obstacle to Progress." Now, Chang uses some pretty harsh language with regard to the Joint Resolution of 1898 ("some cruel and inhuman weapon" is one phrase he uses) but his research is pretty darn good.

During the 1950s, the Senate Committee on Insular and Interior Affairs struggled with the issue of where exactly the boundaries of Hawaii lay. Did they encompass the channel waters between the main islands? Did they include Midway, Palmyra, Johnston Atoll or Kingman Reef?

Between March 1953 and January 1954, the committee drafted and redrafted boundaries before coming up with Committee Print Six. This map excluded the channel waters, since the United States would be obliged to stop any unauthorized ship or submarine using those waters, and a foreign challenge to that stoppage (Chang argues) could cause some uncomfortable questions about the legality of the Joint Resolution. With regard to Palmyra, the issue is a bit trickier.

I'll quote Chang here, since it's his paper:

"It is clear that a leading member of the Senate Committee, Senator Clinton P. Anderson dislike the owners of Palmyra. It is not clear why he disliked them. One theory is that the owners knew that Palmyra, while in the Hawaiian Islands, was not part of the United States. They seem to flaunt this when they refused the Navy the right to condemn their island in World War II. The ostensible reason why the United States could not condemn Palmyra was that it was not territory of the United States.

This was a position that few dared take during World War II. The Navy ended up leasing Palmyra for its air station. At the end of the war, to boot, the Navy was forced to clean up the island when the owners of Palmyra secured a private bill from Congress, Anderson may have been peeved because the owners of Palmyra were not playing along with the plan: one may now that Hawaii is not part of the United States, but one never acts on the basis—or flaunts it in the face of the United States. Anderson wanted Palmyra removed from the State.

To mask the removal of Palmyra, Anderson filled Print Six Hawaii with the names of other islands would be excluded like Johnston and Kingman Reef. There was no reason to exclude Johnston and Kingman because as of 1959 they were not within the state. They were included explicitly to cover the exclusion of Palmyra. It was officially appeared that all three were being excluded because they were distant from the main islands and unpopulated. That was hardly a sincere explanation because there were many other islands of Hawaii that were distant from the eight main islands and unpopulated— but they were not excluded. Senator Daniel Inouye would eventually solve the pesky Palmyra problem by having it bought by the Nature Conservancy and the Fish and Wildlife Service. United States ownership of Palmyra was a much better mask of the lack of United States sovereignty over the island."

Now, if you don't buy Chang's argument about a deliberate omission, you could examine Sen. Anderson's contemporary arguments. In public statements, he said the exclusion of Palmyra was because it would pose difficulties to administer, and because it was uninhabited, it would not be worth the trouble. The final Senate report on the Hawaii Statehood Act says as much.

Sen. Henry Jackson, in 1959, offered a somewhat flippant third answer:

"Palmyra . . . is technically today a part of the city limits of the city of Honolulu. . . . [We] excluded [Palmyra from the state] in deference to my friend from California who felt that Los Angeles might be discriminated against. That would have been the longest city limits in the world of any incorporated city, extending 1,500 miles to Palmyra."