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 Unless we can conclude on the whole record that "the total effect of the law as a safety measure in reducing accidents and casualties is so slight or problematical as not to outweigh the national interest in keeping interstate commerce free from interferences which seriously impede it" we must uphold the statute. There are two notable exceptions to the dormant Commerce Clause doctrine that can permit state laws or actions that otherwise violate the Dormant Commerce Clause to survive court challenges. The first exception occurs when Congress has legislated on the matter. See "Western & Southern Life Ins. v. State