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10 Cal. W. Int'l L.J. 220 (1980)
American Samoa: Decline of a Culture

handle is hein.journals/calwi10 and id is 234 raw text is: AMERICAN SAMOA: DECLINE OF A CULTURE
ARNOLD H. LEIBOWITZ*
It is obvious that in the annexation of outlying and distant
possessions grave questions will arise from differences of race,
habits, laws and customs of the people, and from differences of
soil, climate and production, which may require action on the
part of Congress that would be quite unnecessary in the annexa-
tion of contiguous territory inhabited only by people of the same
race, or by scattered bodies of native Indians.'
American Samoa is an unincorporated territory of the United
States, located approximately 2,300 miles southeast of Hawaii,
nearly halfway between Hawaii and Australia. American Samoa is
comprised of seven islands: five volcanic islands - Tutuila, the
main island where nearly eighty percent of the population lives,
Aunu'u, and the Manu'a group of Ta'u, Olosega, and Ofu - and
two coral islands, Swains Island2 and the uninhabited Rose Island.'
Western Samoa, an independent country since 1962, is racially and
culturally tied to American Samoa. It lies eighty miles to the west
and is considerably larger than American Samoa, with over five
times the population and nearly fifteen times the land area.'
Despite United States recognition of the distinctive Samoan
social structure and culture, Samoa is fighting a losing battle to re-
* President, Institute of International Law and Economic Development; A.B., 1951,
Columbia University; LL.B., 1954, Yale University, College of Law.
This article is part of a constitutional examination of the offshore areas of the United
States and their treatment within the United States federal system. The author wishes to
express his appreciation to the Ford Foundation and the National Science Foundation for
their financial support of this project, and to Linnea Klee for her research assistance.
1. Downes v. Bidwell, 182 U.S. 244, 282 (1901).
2. Swains Island is ethnically unrelated to American Samoa and also somewhat dis-
tant-280 miles away from the islands in the American Samoa group. The United States
has treated it as part of American Samoa since 1925. 48 U.S.C. § 1662 (1976). Residents of
Swains Island are represented in the American Samoa House of Representatives by a non-
voting delegate. AM. SAMOA CONST. art. II, § 2.
3. In addition, there are six miniscule islands administered as part of American
Samoa: Nuu Island and Nuu Silaelae Island lying adjacent to Ofu Island, Sand Island,
Taputapu Island, Pola Island, and Nuusetoga Island. OFFICE OF SAMOAN INFORMATION,
ANNUAL REPORT 46 (1973) [hereinafter cited as ANNUAL REPORT].
4. WEBSTER'S NEW GEOGRAPHICAL DICTIONARY 44, 1324 (1972) (American Samoa
comprises 76 square miles of land with a population of about 28,000; Western Samoa com-
prises 1,133 square miles of land with a population of about 149,000).

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