"Although it could be argued that Midway became part of Hawaii when Middlebrooks discovered it in 1859, it was assumed at the time that Midway was independently acquired by the U.S. when Reynolds visited in 1867, and so was not considered part of the Territory.In defining which islands the State of Hawaii would inherit from the Territory, the Hawaii Admission Act clarified the question, specifically excluding Midway (along with Palmyra Island, Johnston Island, and Kingman Reef) from the jurisdiction of the state.