"Native Hawaiians, like other indigenous cultures, could not grasp the concept of fee simple ownership of land. The concept of owning land was as foreign to them as the concept of owning air would be to us today."
-- Sen. Daniel Akaka, 152 Cong Rec S 5558
Non-lawyer readers, see Wikipedia for a simple explanation of the ad coelum doctrine.
And yes, I really did just need to write a post that had that title.