 While Duke Kahanamoku was a military police officer during World War II, he arrested Lloyd C. Duncan, a civilian shipfitter on February 24th, 1944, following a brawl with two armed Marine sentries at the yard.At the time, Hawaii, not yet a state, was being administered under the Hawaiian Organic Act which effectively instituted martial law on the island, tightened after the attack on Pearl Harbor.Duncan was tried and convicted by a military tribunal for assault on military or naval personnel with intent to resist or hinder them in the discharge of their duty, despite civilian courts at the time having restarted summoning jurors and witnesses and conducting criminal trials on the island; Duncan appealed to the Supreme Court.