Korematsu v. United States

Background:

After the Japanese attack on Pearl Harbor on December 7, 1941, during World War II, fear of more attacks began to spread throughout the United States. Government and military officials began to argue that people with Japanese ancestry living on the West Coast of the U.S. could pose a security threat, despite the fact that there was little to no evidence of such widespread espionage. In February 1942, President Franklin D. Roosevelt signed Executive Order 9066. This authorized military commanders to designate areas and remove individuals whom they classified as threats to national security. As a result of this, more than 110,000 people of Japanese ancestry, most of whom were American citizens, were taken from their homes and forced into internment camps. Instead of simply finding the few people the government believed truly could be threats to security or involved in plans of sabotage, they targeted any people who appeared to have Japanese descent, with no proof they were any threat whatsoever.

The Case:

Fred Korematsu was a 23 year old American citizen, born in California. His parents had immigrated to the United States from Japan before he was born. While many others complied with the relocation orders, Korematsu refused to comply with the relocation orders. He continued to live in the Bay Area and attempted to avoid detection. Eventually, he was arrested and convicted for violating military orders. Korematsu argued that the government’s actions violated his constitutional rights. He reasoned his Fifth Amendment right was not being protected, as he was being targeted solely due to his ancestry. He argued this case until it eventually was brought to the Supreme Court.

Debates From Each Side:

The United States government, represented by Solicitor General Charles Fahy of the Department of Justice, contended that the exclusion orders were necessary military measures during wartime. They claimed the nation was at risk of invasion, espionage, and sabotage after Pearl Harbor. It was claimed, the internment of thousands of Japanese people within the United States was due to military hostility rather than purely racial hostility.

Korematsu, on the other hand, argued the government had violated the rights of American citizens without any evidence of individual wrongdoing. His attorneys maintained that people were being deprived of liberty, held in prisoner camps with barely livable conditions, solely because of their ancestry.

Japanese internment camps were extremely dehumanizing. Camps were placed in desolate areas in extreme environments, often enduring scorching summer heat in deserts, or freezing winter temperatures in thin barracks. Surrounded by barbed wire and guard towers, citizens were forced into hastily built, overcrowded barracks with inadequate facilities. Disregard for individual dignity showed through a lack of privacy in communal spaces, with even bathrooms lacking any stalls, partitions, or doors. Poor sanitation and healthcare provided to these camps led to disease outbreaks such as typhoid and dysentery. Korematsu argued that racial classifications should not justify restrictions on constitutional rights.

Verdict:

On December 18, 1933, the Supreme Court ruled 6-3 against Korematsu. The majority opinion, written by Hugo Black, upheld the exclusion orders. The Court acknowledged that restrictions based on race should face the most careful judicial scrutiny. However, the majority concluded that the government had demonstrated wartime necessity. The court therefore ruled that the exclusion orders were constitutional under the circumstances of WWII. Robert H. Jackson, in a dissent, warned that the decision created a dangerous precedent by allowing the military to restrict civil liberties during wartime. Frank Murphy, similarly, argued that the policy fell “into the ugly abyss of racism”. These dissenting opinions became extremely famous and influential in later decades as time went on.

Legacy:

Korematsu v. United States went on to become one of the most criticized decisions in Supreme Court history. In 1983, a federal court vacated Korematsu’s criminal conviction through a rare coram nobis petition. This was done after archival evidence emerged showing that government lawyers had intentionally suppressed and destroyed intelligence reports, such as those from the FBI, which concluded that Japanese Americans posed no actual military threat or security risk. On November 10, 1983, U.S. District Judge Marylyn Hall Patel formally overturned Korematsu's conviction in the same San Francisco courthouse where he had been convicted as a young man.

As for the internment camps, the forced exclusion of Japanese Americans from the West Coast was rescinded in December 1944. While phased releases began shortly after, the government systematically closed almost all of the camps by the end of 1945. The very last maximum-security camp, Tule Lake, was shut down in March 1946, followed by the formal liquidation of the War Relocation Authority in June 1946.

The overturning of Korematsu’s conviction exposed deep government misconduct. It served as the foundation for the Civil Liberties Act of 1988, which officially apologized to Japanese Americans and provided reparations. Despite this, some argue today that a simple public apology is on no front equal to the damage done to the thousands of Japanese citizens, and can not repair the civil liberties and rights that were stripped away by blatant racism. As far as legal precedent, while District Judge Patel's 1983 ruling vacated Korematsu's criminal record and underlying indictment, only the Supreme Court has the authority to overturn its own precedents. The original Supreme Court ruling that upheld the internment stood for decades until the Supreme Court explicitly declared it "gravely wrong", stating it has no place in constitutional law today, in the 2018 Trump v. Hawaii decision.

This case goes to show how racism can influence legal decisions, executing actions that are morally wrong. This highlights how easy it can be for constitutional rights to be stripped away, especially through the division of people by race. This case remains important today, standing as a foundational warning against the violation of civil liberties in the name of national security. It is remembered today for the reminder that every citizen deserves equal protection under the law, ensuring that such atrocities never repeat themselves.