[4] The position of Chief Justice was subsequently held by Americans Henry Clay Ide from 1893 to 1897 and William Lea Chambers from 1897 to 1899.

[5] Chambers' ruling in the kingship dispute between Malietoa Tanumafili I and Mata'afa Iosefo in December 1898 angered the Germans and led to the Second Samoan Civil War.

[6] After the war ended in 1899, Samoa was partitioned into separate German and American colonies in accordance with the Tripartite Convention which superseded the Treaty of Berlin, abolishing the position of Chief Justice.

[11] The first colonial governor Wilhelm Solf appointed Erich Schultz-Ewerth to the position of Imperial Chief Judge.

[14] John Luxford served as Chief Judge from 1929 to 1935, during which time he was involved in controversies including the inquest into Black Saturday and the deportation of Olaf Frederick Nelson.

[15] After independence in 1962, New Zealand expatriates continued to hold the post of Chief Justice for some years, as in other Pacific Islands Commonwealth countries.

[20] Judges of the Supreme Court, including the Chief Justice, must have eight years' total experience as barristers in Samoa or other approved countries, and must meet other qualifications prescribed by the Head of State, acting on the advice of the Judicial Service Commission.