The law of the splintered paddled was declared by King Kamehameha I in 1797. The law, “Let every elderly person, woman and child lie by the roadside in safety,” is enshrined in the state constitution, Article 9, Section 10, and has become a model for modern human rights law regarding the treatment of civilians and other non-combatants. It was created when Kamehameha was fighting in Puna. While chasing two fishermen (presumably with the intention to kill them), his leg was caught in the reef, and one of the fisherman, Kaleleiki, hit him mightily on the head with a paddle in defense, which broke into pieces. Kamehameha was able to escape, and years later, the same fisherman was brought before Kamehameha. Instead of ordering for him to be killed Kamehameha ruled that the fisherman had only been protecting his land and family, and so the Law of the Splintered Paddle was declared.