Why Good Friday is a Legal Holiday in Hawaiʻi

By Roberta F. Woods, J.D., M.L.I.Sc.

In Hawaiʻi, official holidays are enumerated in the Hawaiʻi Revised Statutes Section 8-1. Because of Hawaiʻi’s history as a Constitutional Monarchy, residents of Hawaiʻi get three additional holidays than many other states, but they also get Good Friday off. The official holidays are:

  • The first day in January, New Year’s Day;
  • The third Monday in January, Dr. Martin Luther King, Jr., Day (added in 1988);
  • The third Monday in February, Presidents’ Day;
  • The twenty-sixth day in March, Prince Jonah Kuhio Kalanianaole Day (added 1949);
  • The Friday preceding Easter Sunday, Good Friday (added in 1941);
  • The last Monday in May, Memorial Day;
  • The eleventh day in June, King Kamehameha I Day;
  • The fourth day in July, Independence Day;
  • The third Friday in August, Statehood Day (renamed in 2001);
  • The first Monday in September, Labor Day;
  • The eleventh day in November, Veterans’ Day (added in 1955);
  • The fourth Thursday in November, Thanksgiving Day (added in 1978);
  • The twenty-fifth day in December, Christmas Day;
  • All election days, except primary and special election days, in the county wherein the election is held;
  • Any day designated by proclamation by the President of the United States or by the governor as a holiday.

Good Friday was added as a legal holiday in 1941. It has been challenged in Cammack v. Waihee, 673 F. Supp. 1524 (D. Haw. 1987), aff’d, 932 F.2d 765 (9th Cir. 1991), reh’g denied, 944 F.2d 466 (9th Cir. 1991), cert. denied, 505 U.S. 1219 (1992). The U.S. District Court for the District of Hawaiʻi examined the legislative history of the statute and concluded that the purpose of including Good Friday as a legal holiday was to increase the number of legal holidays and not for religious reasons. Prior to the enactment of the statute there were no legal holidays from Washington’s Birthday in February to Memorial Day at the end of May, the longest “holiday free” period in the calendar. The Court also found that Good Friday is a traditional shopping day in Hawaiʻi and it cited numerous collective bargaining agreements the state had that included Good Friday as a day off work.

A Little Research About Discoverers’ Day in Hawaiʻi

By Roberta Freeland Woods, Reference and Instructional Services Librarian

In Hawaiʻi, the second Monday in October is not about Christopher Columbus and cannot be a state holiday (HRS 8-1.5):

[§8-1.5]  Discoverers’ Day.  The second Monday in October shall be known as Discoverers’ Day, in recognition of the Polynesian discoverers of the Hawaiian Islands, provided that this day is not and shall not be construed to be a state holiday.

[L 1988, c 220, §4]

The enumerated state holidays are also statutory (HRS 8-1):

§8-1 Holidays designated.  The following days of each year are set apart and established as state holidays:

The first day in January, New Year’s Day;

The third Monday in January, Dr. Martin Luther King, Jr., Day;

The third Monday in February, Presidents’ Day;

The twenty-sixth day in March, Prince Jonah Kuhio Kalanianaole Day;

The Friday preceding Easter Sunday, Good Friday;

The last Monday in May, Memorial Day;

The eleventh day in June, King Kamehameha I Day;

The fourth day in July, Independence Day;

The third Friday in August, Statehood Day;

The first Monday in September, Labor Day;

The eleventh day in November, Veterans’ Day;

The fourth Thursday in November, Thanksgiving Day;

The twenty-fifth day in December, Christmas Day;

All election days, except primary and special election days, in the county wherein the election is held;

Any day designated by proclamation by the President of the United States or by the governor as a holiday.

[L 1896, c 66, §1; am L 1903, c 55, §1; am L 1911, c 167, §1; am L 1915, c 20, §1; am L 1919, c 54, §1; RL 1925, pt of §146; RL 1935, pt of §21; am L 1941, c 132, pt of §1; RL 1945, pt of §21; am L 1945, JR 8, §1; am L 1949, JR 15, §1; am L 1953, c 278, pt of §10; am L 1955, c 9, §1; RL 1955, pt of §1-43; am L 1961, c 116, pt of §1; am L 1965, c 162, §1; HRS §8-1; am L 1969, c 156, §1; am L 1971, c 21, §2; am L 1976, c 220, §2; am L 1978, c 205, §2; am L 1980, c 11, §1; am L 1988, c 220, §1; am L 2001, c 65, §1]