Hawaii hotspot created at least 129 volcanoes, more than 123 of which are extinct volcanoes, seamounts, and atolls, four of which are active volcanoes, and two of which are dormant volcanoes. They can be organized into three general categories: the Hawaiian archipelago, which comprises most of the U.S. state of Hawaii and is the location of all modern volcanic activity; the Northwestern Hawaiian Islands, which consist of coral atolls, extinct islands, and atoll islands; and the Emperor Seamounts, all of which have since eroded and subsided to the sea and become seamounts and guyots (flat-topped seamounts). Hawaiian volcanoes are characterized by frequent
Dormant Commerce Clause state law under the Dormant Commerce Clause came in 1873. Justice Anthony Kennedy has written that: "The central rationale for the rule against discrimination is to prohibit state or municipal laws whose object is local economic protectionism, laws that would excite those jealousies and retaliatory measures the Constitution was designed to prevent." In order to determine whether a law violates a so-called "dormant" aspect of the Commerce Clause, the court first asks whether it discriminates on its face against interstate commerce. In this context, "discrimination" simply means differential treatment of in-state and out-of-state economic interests that benefits the former and