<P> The Office of Hawaiian Affairs of the state of Hawaii, created in 1978, limited voting eligibility and candidate eligibility to native Hawaiians on whose behalf it manages 1,800,000 acres (7,300 km) of ceded land . The Supreme Court of the United States struck down the franchise restriction under the Fifteenth Amendment in Rice v. Cayetano 528 U.S. 495 (2000), following by eliminating the candidate restriction in Arakaki v. State of Hawai'i a few months later . </P> <P> Citizens of the nation's capital, Washington, D.C., have not been apportioned a representative or US senator in Congress . This is because D.C. is a federal district and not a state and under the Constitution, only states are apportioned congresspersons . </P> <P> District of Columbia citizens had voting rights removed in 1801 by Congress, when Maryland delegated that portion of its land to Congress . Congress incrementally removed effective local control or home rule by 1871 . It restored some home rule in 1971, but maintained the authority to override any local laws . Washington, D.C., does not have full representation in the U.S. House or Senate . The Twenty - third Amendment, restoring U.S. Presidential Election after a 164 - year - gap, is the only known limit to Congressional "exclusive legislature" from Article I - 8 - 17, forcing Congress to enforce for the first time Amendments 14, 15, 19, 24, and 26 . Amendment 23 gave the District of Columbia three electors and hence the right to vote for President, but not full U.S. Congresspersons nor U.S. Senators . In 1978, Congress proposed a constitutional amendment that would have restored to the District a full seat for representation in the Congress as well . This amendment failed to receive ratification by sufficient number of states within the seven years required . </P> <P> As of 2013, a bill is pending in Congress that would treat the District of Columbia as "a congressional district for purposes of representation in the House of Representatives", and permit United States citizens residing in the capital to vote for a member to represent them in the House of Representatives . The District of Columbia House Voting Rights Act, S. 160, 111th Cong . was passed by the U.S. Senate on February 26, 2009, by a vote of 61 - 37 . </P>

Who was allowed to vote in the early republic