[This essay is the second item in the book The Dispossession of the American Indian And Other Key Issues in American History (Washington, D.C.: Scott-Townsend Publishers, 1995). It also appeared as an article in The Journal of Social, Political and Economic Studies, Spring 1993; and in Conservative Review, January/February 1993.]


Dedication as it appears in the book: I am pleased to dedicate this collection of essays to Lillian Baker, a woman of great attainment and courage. She has been the leader in the effort to make available to the American people an accurate account of the relocation of the Japanese-Americans from the west coast during World War II. To that end, she has combined exhaustive scholarship with a profound love for the United States of America.



            As I checked some books out of the Wichita State University library just before beginning to write the article upon which this chapter is based, the young librarian noticed the subject of the books--the so-called "internment" of the Japanese-Americans during World War II--and offered the information that "there's an excellent book that arrived recently about the internment of the Japanese-Canadians in Canada. Canada did the same thing we did!"

            He was surprised when I said that "there were substantial differences. The Canadians actually interned them, which we didn't--and didn't let them return to the west coast of Canada until 1949.1 Did you know that in this country we sent their college-age young people to hundreds of American universities?"

            "After the war?"

            "No, during the war."

            That ended the conversation. He lost relish for it when it became obvious that I didn't hold the politically correct view on the subject.

            It is doubtful whether in talking to the young librarian I had stumbled upon anyone particularly radical. It is more likely that his perceptions reflect the well-nigh universal understanding among "the (properly) informed public" on such issues as the relocation of the Japanese-Americans, Kent State, the Hollywood Blacklist, etc.--which is that Americans have shown their true colors by a series of bigoted, essentially vicious, acts. Among that "informed public" there is even a certain delight in it, as though it is a vindication of all they know. Many Americans think it a sign of objectivity and generosity of spirit to want to believe the worst about the United States.

            What is important to a student of today's on-going but one- sided "war over American culture" is to realize that these perceptions are a result--one of the many legacies--of the Sixties (which in turn had raised to a fever pitch the hostile cultural critique that the Left had been making of "bourgeois" society since the 1820s). Dr. Ken Masugi, then a resident fellow at the Claremont Institute, stated the point succinctly in 1984 when he testified before Congress that the currently-accepted view is the product of "Japanese-Americans who were activists in the Sixties and then became lawyers and community organizers." The intent, he said, is to achieve "one of the goals of the Sixties protest movements: To show that America is a racist society, and that even in the case of World War II, America's noblest foreign war, America was corrupt, having its own 'concentration camps.'"2

            Before the New Left, very little was heard about the World War II relocation of the Japanese-Americans. According to the 1982 Report of the Commission on Wartime Relocation, "those representing the interests of civil rights and civil liberties in Congress, the press and other public forums were silent or indeed supported exclusion...A poll of the Northern California Civil Liberties Union in the spring of 1942 showed a majority in favor of the evacuation orders." Nor was there any opposition in Congress.3 At the end of the war, the Japanese-Americans themselves who fought in Italy and France raised funds for a memorial to President Franklin Delano Roosevelt. So we can see that although the evacuation raises issues all Americans should consider, it is largely an issue born out of more recent cultural alienation.

            An interesting aspect is that the cognoscenti's perception of American viciousness does not take as its target simply a certain 'redneck' portion of the American population. The New Left turned its anger every bit as much against "liberals." With regard to the Japanese-American issue, those who are alienated do not shrink from denouncing as guilty the Franklin Delano Roosevelt administration and such personalities as Earl Warren and Milton Eisenhower.

            As with all these things, the ideas become as common as the air we breathe. That is made especially evident when an idea appears in the "Dear Abby" newspaper feature. On April 13, 1992, Abigail van Buren was so proud of something she'd written years ago that she repeated it: "In 1980 I wrote: 'To our everlasting shame, approximately 100,000 loyal American citizens were held in concentration camps for the duration of World War II. Their "crime"? They were of Japanese descent.'"

It's time for an honest look

            When I started my study of the removal of the Japanese- Americans I knew virtually nothing about it, and I have remained ready to report whatever I found. It obviously should not be a disqualification, though, for a scholar to begin his study of any of these issues without a prior animus against the United States.

            Nor should proving the scholar's "objectivity" require him to find reason for America to be ashamed when that isn't called for. In my opinion, the United States did not act shamefully in its treatment of persons of Japanese ancestry during World War II. In fact, a better case could be made for a diametrically opposite criticism: that the treatment was so tender-hearted that it actually endangered the security of the United States during a desperate war.

            In the intolerant context of today's ideological arguments, it is predictable that a conclusion favorable to the United States will be represented as "offensive" to the many splendid people of Japanese ancestry who now form a part of the American people. But that, of course, is nonsense. The search for historical accuracy isn't a panderer's game to curry favor. To seek the truth is no slander against anyone.

            I was among those who were thrilled when Kristi Yamaguchi received her Olympic gold medal in skating at Albertsville, France, to the strains of the American national anthem. She has represented this country beautifully with her 1991 world championship in Munich and her U.S. national title in Orlando early in 1992. And there is no question but that America lost a splendid citizen with the death in 1992 of S. I. Hayakawa. In a more normal climate it would go without saying that no insult is intended to the likes of Yamaguchi or Hayakawa by an honest study of the World War II removal issue.

The topics we will examine

            There is so much to the subject that it will be helpful for me to start, like a debater, by "telling you what I am going to tell you." Most of what follows will relate to two large questions:

. First, what exactly was done regarding the persons of Japanese ancestry?

. Second, why was it done?; i.e., what was its necessity?

            Each of these involves a many facets. When we have finished them, we will review the U.S. Supreme Court decisions relating to the issue and tell of the various follow-ups in the form of Congressional inquiries, a Presidential commission, and the payment of damages on two occasions.

Some terms to know

            Anyone dealing with this issue soon gets to know the names that have been given in Japanese to the various groups that have come to this country. The generic name that applies to all those in the United States who are of Japanese origin is "Kikkei." Of these, the "Issei" are those who came to this country as immigrants, the "Nisei" are the first generation born in the United States, and the "Sansei" the second. There is a separate word--"Kibei"--for those who returned to Japan for their education.

            Although I include these names as information, I will use them sparingly, since I think most readers will find them more confusing than helpful.


The Japanese-American presence on the West Coast

            Japan followed a policy of strict separation from the remainder of the world from 1638 until Commodore Matthew C. Perry broke its isolation in 1854. The Japanese government placed strict limits on emigration until in 1884 it granted the right to emigrate freely. A few Japanese came to the United States before the turn of the century.

            Between 1901 and 1908, however, both the United States and Japan allowed unrestricted migration from Japan--and 127,000 Japanese came to this country, almost all settling on the West Coast. This immigration was sharply restricted in 1908, and a "Gentleman's Agreement" was entered into with Japan limiting the flow, after which Japanese continued to enter in lesser numbers. Immigration from Japan was barred totally beginning in 1924. American law did not provide for citizenship for those who had come, but those who were born in the United States automatically became citizens, and had dual citizenship with Japan. The 1940 Census showed 126,947 persons of Japanese origin in the United States; of these, 79,642 were born here.4

Immediate arrest of "dangerous aliens" after Pearl Harbor

            Within days after the December 7, 1941, Japanese attack on Pearl Harbor, approximately 3,000 Japanese aliens classified as dangerous were arrested and incarcerated by the Department of Justice. These were individuals under suspicion by American intelligence agencies, which beginning in 1939 had begun to compile lists of persons considered dangerous in case of war.5 (This group was included among those who received an apology and $20,000 each in the early 1990s for "mental suffering.")

Declaration of the West Coast as a military zone; exclusion of persons of Japanese origin

            On February 19, 1942, President Franklin D. Roosevelt signed Executive Order 9066. This authorized the establishment of military areas from which people of all kinds could be excluded.6 Lt. General John L. DeWitt was appointed the military commander to carry out the Executive Order. In March, Gen. DeWitt declared large parts of the Pacific Coast states military areas in which no one of Japanese descent would be allowed to remain. The exclusion order affected Japanese-Americans living on the West Coast by forcing them to move inland. Its only effect upon those who already lived inland was to bar them from going to the quarantined areas on the West Coast.

            Col. Karl R. Bendetsen was named Director of the Wartime Civil Control Administration to handle the evacuation. Also in March, Roosevelt created a civilian agency, the War Relocation Authority (WRA), to assist the evacuees. Milton Eisenhower, brother of later president Dwight Eisenhower, was named Director. Congress ratified the evacuation by enacting legislation that made it a federal offense for anyone to violate the exclusion order.

            A short-lived plan originally was to assist the Japanese- Americans in a process by which they would move inland "on their own recognizance" as individuals and families. Bendetsen says that "funds were provided for them [and] we informed them...where there were safe motels in which they could stay overnight."7 This was ended almost immediately, by late March, however; Bendetsen says that the need for a more organized system became apparent when most of the Japanese-Americans were not able to make arrangements to relocate quickly even with some help.8 A second reason was that the governors of western states (reflecting public opinion in their states) objected strongly to thousands of people of Japanese origin moving into their states without oversight.9 These objections were reiterated at a Governors' Conference for ten western governors on April 7. (There was a continuing tension, lessening over time, between the desire to let the evacuees relocate freely and the public's desire to have them closely monitored.)

            This led to the "assembly center phase," during which the evacuees were moved to improvised centers such as race tracks and fairgrounds along the West Coast pending the construction of ten "relocation centers" in eastern California, Arizona, Utah, Idaho, Wyoming, Colorado, and as far east as Arkansas. During this phase, federal officials made extensive efforts to lessen public hostility. As those feelings subsided, approximately 4,000 families moved inland "on their own recognizance" to communities of their choice before the assembly center phase was over at the end of the summer of 1942. Bendetsen says that all of the Japanese-Americans could have moved on their own at any time if they had seen their way clear to do it.10

            The assembly centers are criticized as having had "barbed wire and searchlights," overcrowding, lack of privacy, and inadequate medical care. But Bendetsen disputes virtually all of this, as we will see in my later discussion of whether the evacuees can properly be said to have been "interned."

            Hastily improvised and purely temporary quarters for thousands of people who have been uprooted from their homes on short notice could not have been pleasant. There is no incongruity, however, between this and the fact, also true, that the government worked with the evacuees to take extraordinary measures to make the centers as comfortable as possible. In the short time they existed, some centers opened libraries; movies were shown regularly; there were Scout troops, arts and crafts classes, musical groups, and leagues for basketball and baseball. Three hundred and fifty people signed up for a calisthenics class at Stockton. All had playgrounds for children, and one even had a pitch-and-putt golf course.11 The centers were run almost entirely by the Japanese-Americans themselves.12

            As the ten relocation centers became ready, the evacuees were moved to them from the assembly centers. These were under the jurisdiction of the War Relocation Authority. Dillon S. Myer became the Director of the WRA in June when Milton Eisenhower resigned to become the deputy director of the Office of War Information. The relocation centers' highest population, of 106,770, was attained on November 1, 1942.13 The construction of the camps was of the type used for housing American soldiers overseas14--which is to say, the centers were austere but functional. Senator S. I. Hayakawa later described them as "dreary places: long rows of tarpaper-covered wooden barracks...Each room had a stove, a drop light, an iron cot and mattress...But the WRA," he said, "headed by the wise and humane Dillon Myer,...made life as comfortable as possible for them."15 It is worth noting that no families were ever separated during the process.16

            As with the assembly centers, the critics find fault with much about the relocation centers. For example, the health care has been the subject of continuing dispute.17 Dillon Myer, however, says that "the professional care was excellent [and] was free."18

            There were messhalls for meals, and a large number of community enterprises, which included stores, theaters, hairdressers, community theaters, and newspapers. There was ping-pong, judo, boxing, badminton, and sumo wrestling.19 Again, there were basketball and baseball leagues (along with some touch football). The Santa Fe center had "gardens, two softball diamonds, two tennis courts, a miniature nine-hole golf course, a fenced forty-acre hiking area,...classes in calligraphy, Chinese and Japanese poetry...."20 The Massachusetts Quakers sponsored art competitions. Libraries featured Japanese-language sections. There were chapters of the American Red Cross, YMCA, YWCA, Boy Scouts, and Girl Scouts. State Shinto, with its emperor-worship, was barred, but otherwise the evacuees worshipped as they pleased. The government paid a salary equal to an American soldier's pay ($21 per month) to those who worked in the centers.21

            Each of the camps (except Tule Lake, which came to be quite different from the others for reasons we will see later) had fully accredited schools through the high school level. There were nursery schools, kindergarten, the teaching of instrumental music, school choruses, achievement testing, high school newspapers and annuals, dances, active Parent-Teacher Associations, student councils and class officers. When graduation was held at the Topaz camp, the University of Utah lent the necessary caps and gowns. 22 Present-day critics such as Lane Ryo Hirabayashi, however, reflecting the ideology of today's 'multiculturalism,' object to the assimilationist objectives of the instruction, which sought to Americanize the students.23 (This is inconsistent with the criticism that is also made, again with bitter charges of "racism," that during the 1920s and 1930s Americans hadn't welcomed an assimilation of Japanese immigrants, and had enacted laws to prevent it.)

            Much of the credit for the livability of the centers goes to the Japanese-Americans themselves, whose energy and intelligence immediately made the best of the situation. This was accomplished in an active relationship with the WRA.

            Subject to a veto that the WRA could exercise, each relocation center was governed internally (as had been the assembly centers) by the Japanese-Americans themselves, who elected representatives from each block.24

            Even before the relocation centers became filled, college-age students began to leave to attend American universities. By the beginning of the fall semester in 1942, approximately 250 students had left for school, attending 143 colleges and universities. By the time the war was over, 4,300 college-age students were attending more than 300 universities around the country (though not on the West Coast).25 Scholarships were granted based on financial ability. Foundations and churches funded a "National Japanese American Student Relocation Council" to help with college attendance.26

            The centers were intended, as their name suggests, to be places in which the evacuees could stay while they were being relocated around the country. Myer says "never was there any policy of confinement for the duration."27 "As early as September 1942," S. I. Hayakawa tells us, "hundreds of Issei railroad workers were restored to their jobs in eastern Oregon."28 At one point, $4 million was appropriated to help those who wanted to start businesses away from the centers. In 1943, 16,000 people left the centers on indefinite leave; and 18,500 more followed in 1944. Others left the centers on a seasonal basis, such as the 5,000 who helped harvest the sugar beet crop in several western states.29 Field offices were maintained by the WRA in midwestern and eastern cities to find jobs for those willing to go out on their own. Churches maintained hostels in four cities to provide short-term quarters for those who wanted to leave the centers to look for jobs.30 It is for all of these reasons that those who were in charge say that relocation, not internment, was the goal. That is why the camps were called "relocation centers" rather than "internment camps."

            Many of the evacuees, however, remained in the centers for the duration of the war. Critics attribute this to a lack of alternatives, as though the evacuees were trapped, but Bendetsen credits the fact that life was acceptable within the centers. "Many elected to stay in the relocation centers while being gainfully employed in nearby pursuits in the general economy... The climate of hostility which presented intractable problems in the very early phases had long since subsided."31

            Beginning in early 1944, with still a year and a half of war remaining, "certificates of exemption" began to be issued to those who, having passed security investigations, wanted to return to the West Coast. Then in November 1944 FDR's cabinet decided to lift the exclusion. This was announced by the War Department on December 18 and took effect on January 2. With that, the process of disassembling the centers got underway. The war with Japan ended in August 1945, and the last of the centers, except Tule Lake, was closed on December 1, 1945.

Tule Lake Center used for actual internment

            The center at Tule Lake, California, started as a relocation center but was soon turned into an actual internment camp--a "segregation center"--for those Japanese-Americans who were hostile to the United States.32 It housed those who applied to be repatriated to Japan if they had not withdrawn the application by the middle of 1943; those who answered "no" to a loyalty questionnaire and didn't clear up the problem in special hearings held for the purpose; those against whom the government had evidence of disloyalty; and the family members of those in the first three groups.33 (All of these were latter among the recipients of the $20,000.)

Were the relocation centers an "internment"?

            There is no question but that the evacuees were forced by law to leave their homes on the West Coast and to either stay in the centers or relocate elsewhere in the United States by receiving leaves for the purpose. Their exclusion from the West Coast was not voluntary, and after the short-lived initial phase their relocation had to be done through the centers, which granted leave, temporary or indefinite, for the purpose. But, except for those arrested as 'dangerous aliens' right after Pearl Harbor and those who were later segregated at Tule Lake, were the Japanese-Americans "interned" in the centers? And were the centers, as is often charged, "concentration camps"?

            It is important to realize that these questions are largely issues of characterization. Those who want to place the evacuation in the worst light stress the "humiliation" and "affront to our loyalty" inherent in being made to relocate. They especially like to speak of the centers as "concentration camps," thereby evoking images of the horrors of Nazi concentration camps. (One of the many books on the subject speaks of "the parallel experience of the German Jews.")34 Even Senator Hayakawa, who felt no alienation toward the United States, later spoke of the evacuation as an affront that said in effect that "we doubt your loyalty."35 (I have difficulty accepting even Hayakawa's notion about this, since the evacuation was premised not on a doubt about the loyalty of all Japanese-Americans but on an inability quickly to sort out who was loyal to the United States and who to Japan. The officials of the Roosevelt administration always acknowledged that a great many of the Japanese-Americans were loyal.)

            The substance of the charge of "internment" is contradicted by the fact that resettlement outside the centers was diligently pursued throughout the process. Hayakawa says that by January 2, 1945, half of those evacuated had "found new jobs and homes in mid-America and the East."36

            What is most often pointed to in support of the charge of "internment" and even of the centers' being "concentration camps" is that there were "fences and guards." Even Hayakawa speaks of the centers as being "behind barbed wire, guarded by armed sentries."37 Oddly, however, the role of fences and guards depends largely upon perception.

            In 1984 a House subcommittee asked Bendetsen about earlier testimony that there had been barbed wire and watchtowers, and he testified that "that is 100 percent false...Because of the actions of outraged U.S. citizens, of which I do not approve, it was necessary in some of the assembly centers, particularly Santa Anita,...to protect the evacuees...and that is the only place where guards were used. [As to] relocation centers...there was not a guard at all at any of them. That would not be true of Tule Lake [after it became a segregation center]."38

            I have studied the follow-up questioning by the subcommittee's counsel to see whether any effort was made to attack Bendetsen's testimony by confronting him with specifics that would contradict it. He had testified to the same effect in 1981 and the subcommittee staff could easily have been prepared with specifics to ask him about if they existed.

            I have given the same scrutiny to the questioning at the time he testified before the Commission on Wartime Relocation in 1981. In neither case were specific follow-up questions asked, despite many allegations to the subcommittee and earlier to the Commission that the centers were guarded. Although the conflict in reports isn't definitively resolved in my mind, I assign considerable weight to this failure to cross-examine Bendetsen about specifics, which should have been known to the subcommittee and the Commission, when there was time and opportunity to do so.

            In 1981 Senator Brooke had asked him in general terms about "the voluminous testimony we have had describe [sic] these camps quite differently from the way you've described them." Bendetsen replied: "A great part of the testimony was given by people who were not yet born then...You had testimony available from many people who were not given an opportunity to present it, some of whom were physically intimidated by the people who were in attendance day after day...I have received a barrage of mail... There were many people who in good faith wanted to testify that they thought the conditions were nowhere close to some of the testimony which you heard."39

            Photographs are provided in some of the literature showing watchtowers and guards. As to each photograph, it is important to know the specific date and location. The persons at Tule Lake, for example, were under guard to keep them in; and photographs from early 1942 would relate to the assembly center phase.

            As we will see in my discussion of the military situation, there were strong reasons for an actual internment, which is what Earl Warren, then the attorney general of California, wanted. But that is not what the Roosevelt administration did. It chose to steer a middle course between those who wanted no evacuation at all and those who, like Warren, wanted the Japanese-American population closely monitored. To call it an "internment" is at most a half-truth. (I should point out, too, that the word "internment" has a specific legal meaning that applies, say, to the Department of Justice incarceration of those who were arrested on security grounds but that does not apply to the relocation centers.40 This is worth noting, even though in my discussion here I am more concerned with the substance of what was done than with the semantics of the law.)

Economic losses; care of property

            Unscrupulous people took advantage of the situation in which the Japanese-Americans found themselves between the time of Pearl Harbor on December 7, 1941, and early March of the following year.41 But once the Army took charge of the evacuation, extensive efforts were made to safeguard the evacuees' property. Col. Bendetsen testified:

            When you are told that the household goods of the evacuees after I took over were dissipated, that is totally false. The truth is that all of the household goods of those who were evacuated or who left voluntarily were indexed, stored, and warehouse receipts were given. And those who settled in the interior on their own told us, and we shipped it to them free of charge. As far as their crops were concerned, the allegations are totally false. I used the Agriculture Department to arrange harvesting after they left and to sell the crops at auction, and the Federal Reserve System, at my request, handled the proceeds. The proceeds were carefully deposited in their bank accounts in the West to each individual owner. And many of these farms were farmed the whole time--not sold at bargain prices, but leased--and the proceeds were based on the market value of the harvest.42

            As we will see, Congress passed a "Claims Act" in 1948 under which approximately $38 million was paid to the evacuees for property losses. The critics assert that additional compensation should have been granted for mental suffering, but that is a different issue than whether there was a wanton taking of their property. Many millions of people, including Americans of all origins and by no means limited to the Japanese-Americans, experienced uncompensated mental suffering in World War II.


The nature of the military emergency

            A situation of extreme military vulnerability existed in December 1941 and early 1942. The American Pacific Fleet, the United States' first line of defense in the Pacific, was destroyed by the December 7 Japanese attack on Pearl Harbor. The Japanese at the same time attacked Hong Kong, Malaysia, the Philippines, Wake and Midway Islands. The next day, they invaded Thailand. Within less than a week, Guam fell. By Christmas they had taken Wake Island and had occupied Hong Kong. Manila fell on January 2, and Singapore on February 10. The Battle of the Java Sea on February 27 resulted in a major Japanese naval victory. By early March Japan had control over Rangoon, Burma and the Netherlands East Indies.43 The struggle at Bataan and Corregidor marked the end of the Japanese conquest of the Philippines. The Hawaiian Islands and the West Coast of the United States were unprotected from attack. On February 23 a Japanese submarine shelled an oil field along the California coast.44 Two days later five unidentified planes were spotted and Los Angeles underwent a black-out. The United States hurriedly made preparations for war.45 The extent of its unpreparedness is graphically illustrated by the draftees' use of wooden guns in their maneuvers in Louisiana in early 1942.46

Japanese exploitation of West Coast vulnerability

            The critics of the evacuation often argue that there was no demonstrated military necessity for it. The Report of the Commission on Wartime Relocation speaks of "the clamor" by California officials for protective action, and says that "these opinions were not informed by any knowledge of actual military risks."47 The extensive critical literature mocks the perception of danger, suggesting that it was a figment of hysterical imaginations.

            But this is nonsense. The danger was apparent to anyone who considered the situation. Earl Warren, as attorney general of California, testified before a select committee of Congress (the "Tolan Committee") on February 21, 1942, and submitted letters from a number of local officials. Some pointed to the vulnerability of the water supply and of the large-scale irrigation systems: "It would be absolutely humanly impossible," one of them wrote, "for the small force now available in the sheriff's office to make even a pretense of guarding this tremendous farm territory and the irrigation system."48 Another pointed out that "a systematic campaign of incendiarism would cause terrific disaster" during the California dry season from May until October.49 The city manager of Alameda observed that "we have the naval air station at one end of the island...There are five major shipyards along the northern edge and there is the Oakland Airport at the eastern end of the island."50 Warren provided maps that showed that the Japanese-American population lived in close proximity to virtually all strategic locations.51

            Many scenarios suggest themselves. Espionage, sabotage and aid to an invading army are obvious possibilities. To appreciate the danger we need a very real sense of what a terrible toll could have been exacted if even another Pearl Harbor had been committed. The potential, however, was for much more than that.

            In addition to the civilian population, there was much that was important militarily and economically along the West Coast; it was clearly exposed; and there were few means to defend it. This was enough in itself to create a critical emergency, to be met as humanely but as effectively as possible. It should not be necessary for the American government to have known specifically of plans for espionage and sabotage.

            Just the same, there was definitive evidence of Japan's intent to exploit (and actual exploitation of) the situation. On December 4, 1941, the Office of Naval Intelligence reported a Japanese "intelligence machine geared for war, in operation, and utilizing west coast Japanese."52 On January 21, 1942, a bulletin from Army Intelligence "stated flat out that the Japanese government's espionage net containing Japanese aliens, first and second generation Japanese and other nationals is now thoroughly organized and working underground," according to the testimony of David D. Lowman, a retired career intelligence officer who has written extensively on declassified intelligence from World War II.53

            The Commission on Wartime Relocation contradicted this in its 1982 Report when it said that "not a single documented act of espionage, sabotage or fifth column activity was committed by an American citizen of Japanese ancestry or by a resident Japanese alien on the West Coast."54 This claim is often repeated in the critical literature, but is blatantly false.

            Amazingly, the Commission ignored the most important source of information about espionage, which is the dispatches sent by the Japanese government to its own officials before and during the war. U. S. Navy codebreakers had broken the Japanese diplomatic code in 1938, and the decoded messages were distributed, on a basis "higher than Top Secret," to a small handful of the very highest American officials under the codename "MAGIC." Lowman testified in 1984 that "included among the diplomatic communications were hundreds of reports dealing with espionage activities in the United States and its possessions...In recruiting Japanese second generation and resident nationals, Tokyo warned to use the utmost caution...In April [1941], Tokyo instructed all the consulates to wire home lists of first- and second-generation Japanese according to specified categories." The result, he said, was that "in May 1941, Japanese consulates on the west coast reported to Tokyo that first and second generation Japanese had been successfully recruited and were now spying on shipments of airplanes and war material in the San Diego and San Pedro areas. They were reporting on activities within aircraft plants in Seattle and Los Angeles. Local Japanese...were reporting on shipping activities at the Bremerton Naval Yard...The Los Angeles consulate reported: 'We shall maintain connections with our second generation who are at present in the Army to keep us informed'...Seattle followed with a similar dispatch."55

            Several officials within the Roosevelt administration opposed the evacuation of the Japanese-Americans from the West Coast, but Lowman makes a telling point: that the President, the Secretary of War, the Army Chief of Staff, the Director of Military Intelligence, the Secretary of the Navy, the Chief of Naval Operations, the Director of Naval Intelligence, and the Chiefs of Army and Navy Plans--all of whom received MAGIC-- favored evacuation. It was those who did not have knowledge of the Japanese dispatches who found it possible, somewhat incongruously in light of the self-evident factors I have mentioned, to doubt the military necessity.56

            Critics who damn the United States for the evacuation have sought to minimize the significance of MAGIC. John J. McCloy, who was Assistant Secretary of War during the war, testified in 1984 that "word has gone out now from the lobbyists to 'laugh off' the revelations of MAGIC."57

            The Commission on Wartime Relocation, established by Congress in 1980 and composed of such prominent figures as Arthur E. Goldberg, Arthur S. Flemming, Senator Edward Brooke, and Robert F. Drinan, didn't bother to laugh MAGIC off--it simply ignored it. McCloy testified in 1984 that "proof that the Commission did not conduct an investigation worthy of the name is demonstrated by the fact that it never identified the existence of MAGIC...This should have been presented at the outset of any objective investigation." He pointed out that "though the existence of MAGIC was a closely guarded secret at the time of the attack [on Pearl Harbor], by the time [of] the Commission's investigation the existence of MAGIC was almost notoriously known by all knowledgeable military and intelligence sources in this country and Japan, as well."58

The unassimilated nature of the Japanese-American community

            The nature of the Japanese-American community on the West Coast at the time of World War II posed a dual problem. Because it was tightly-knit and unassimilated, it was attractive to Japan as a field for cultivation. At the same time, it was virtually impenetrable to efforts of the American government to sort out those whose loyalties were with Japan.

            On the Supreme Court, Justice Stone wrote that "there is support for the view that social, economic and political conditions which have prevailed since the close of the last century...have intensified their solidarity and have in large measure prevented their assimilation." Stone estimated that as many as 10,000 of those born in the United States had "been sent to Japan for all or part of their education." He observed that even those who stayed in the United States to go to school "are sent to Japanese language schools outside the regular hours of public schools in the locality."59 S. I. Hayakawa wrote that it was true that "reverence for the emperor was taught in the Japanese-language schools."60 (He added that what was not known was that the children had nevertheless grown up to be loyal Americans. But, as we will see, so sweeping a generalization isn't justified, since not all did.)

            The critics blame American caucasians for this lack of assimilation, pointing to the hostility that had been shown toward Asian immigrants by labor unions and others on the West Coast during the preceding decades. That, though, is another issue, one that asks whether it is wrong for the citizens of a country to oppose large-scale immigration by people who are considerably different from themselves. What is relevant to the question of the military emergency during World War II is not who was at fault for the Japanese-American community's lack of assimilation, but the uncontradicted fact that they were not assimilated.

            An odd thing about the critical literature, now quite voluminous, is that it never speaks to an obvious question: What precisely was going on inside the Japanese-American community during the years and months prior to and immediately after Pearl Harbor? I should think that those who argue that there were virtually no pro-Japanese loyalists among the Japanese-Americans would devote considerable attention to showing just how the internal dynamic of that community worked to assure that. We are expected to believe, as though it's a given, that a "racist" America's attractions were so obvious that no one would look back longingly to Japan, despite strong continuing ties with the mother country. The literature is strangely silent about this aspect, which could provide important information.

How loyal were the Japanese-Americans?

            This brings us to the most sensitive part of the study, since the "politically correct" thing to say is that all of the second-generation Japanese-Americans (the Nisei, who were the first to be born here, and even the Kibei, who were sent back to Japan for their education) were pro-American. I have already referred to Senator Hayakawa's sweeping generalization, which is bound to be appealing: "They had grown up loyal Americans." Accordingly, it is important to note again that it is no reflection on today's Americans of Japanese ancestry to take an honest look at what the situation was fifty years ago during World War II.

            Many did strongly identify with the American side, and even distinguished themselves in combat on behalf of this country. An all-Nisei National Guard unit from Hawaii, the 100th Battalion, fought in Italy, winning much distinction, and was later merged into a newly-formed group, the 442nd Combat Team, which went on to fight in both Italy and France. In all, close to 9,000 Japanese-Americans served with these units. They were honored by President Truman in 1946 after a parade down Constitution Avenue, and in turn raised money for a memorial to President Roosevelt. An additional 3,700 Nisei served as translators and interpreters in the Pacific Theater. In all, out of the combined mainland and Hawaiian Japanese-American populations, a total of more than 33,000 are said to have served in some capacity during the war (although the figure is disputed as being too high).61

            To focus exclusively on this, however, obscures the truth, which taken as a whole was much more complex. Here are some aspects of that complexity:

. The War Relocation Authority had the evacuees fill out a questionnaire about their loyalty. Colonel Frederick Wiener testified in 1984 that "they asked first of the persons of military age whether they would serve in the Armed Forces of the United States; 94 percent of them gave negative answers. Now I will admit that it is asking a great deal of an individual after he is interned as a security risk [sic] to volunteer cheerfully for service...I do not criticize it. What I criticize is that the 94 percent who didn't serve now wrap themselves in the regimental colors of the 442d RCT."62

. A significant number sought repatriation to Japan. 9,028 applications were filed by the end of 1943, a total that swelled to 19,014 by a year later. Eventually, more than 16 percent of the evacuees asked for repatriation. Of these, 8,000 actually went back to Japan. In 1982 the Congressional Commission put the most favorable spin on this by blaming it on the evacuation: "No other statistics chronicle so clearly as these the decline of evacuees' faith in the United States."63 In any case, it runs clearly counter to the example set by those who served in the 442nd Combat Team.

. There was a powerful pro-Japan element within the relocation centers, forcing its members' eventual segregation into the facility at Tule Lake. Secretary of War Henry L. Stimson wrote in May 1943 about "a vicious, well-organized, pro- Japanese group to be found at each relocation center. Through agitation and violence, these groups gained control of many aspects of internal project administration, so much so that it became disadvantageous, and sometimes dangerous, to express loyalty to the United States."64 In the fall of 1942 some of the leaders of the Japanese American Citizens League were beaten by gangs after passing a resolution supporting the United States.65 Sometimes the pro-Japan element formed a competing system of center governance, electing its own block representatives. At the Manzanar center, a group called the Black Dragons championed Japan.66

            There were crises at Poston and Manzanar. On November 1, 1942, a suspected pro-American "informer" was beaten, and after two men were arrested for the beating a crowd of approximately 1,000 people demanded their release and called a "general strike."67 The next month at Manzanar six men in masks attacked another suspected "informer." After an arrest, a mass meeting demanded the suspect's release. Military police tried tear gas, and opened fire, killing two, when someone in the mob started an empty car and headed it toward them.68

            After those who supported Japan were separated off into the Tule Lake center, beatings continued of those who cooperated with the Americans, and one was killed.69 The militants at Tule Lake formed into two groups. John J. Culley, an author who writes as part of the critical literature, tells us that "both groups practiced nationalistic activities with military overtones, including marching and drilling, bugle calls, playing the Japanese national anthem, celebrating the eighth of each month in commemoration of the attack on Pearl Harbor, wearing short military-style haircuts, and wearing rising-sun emblems on their coats and shirts."70

. If Japan had invaded the West Coast, enormous pressures would have come to bear to support the invading army. Col. Bendetsen testified that wherever the Japanese invaded they shot those of Japanese ancestry who did not embrace them--and that this fact was well known.71

. An incident occurred in the Hawaiian Islands that doesn't reflect on the loyalty of the Japanese-Americans in general, but that did sound a chilling warning (as well as contradict the bland assertion that "all Japanese-Americans were of course loyal"). When he testified in 1984, David Lowman cited a 1942 naval intelligence report: "A Japanese airplane attacking Pearl Harbor on Dec. 7 was damaged and forced to make a forced landing on Niihau, one of the smaller Hawaiian islands. There were only 136 people on the island. Three of them were Japanese--one a resident Japanese alien and the other two (man and wife) were Japanese Americans. All three of them allied themselves with the pilot...[They] took over the island, holding people hostage, tying up the others, and burning several buildings to the ground while they waited for a Japanese submarine to come and pick them up. After six days of terror, the Japanese pilot was attacked and killed by a Hawaiian whom he had shot. The pilot's principal co-conspirator, a Japanese American named Harada, committed suicide." The report said that the two Japanese-Americans who collaborated with the pilot "had previously shown no anti-American tendencies."72

A question long-since forgotten: Was mere relocation a dangerously indulgent policy?

            Many officials on the West Coast and in the western states wanted actual internment, not just relocation, for the duration of the war. Hindsight shows that this wasn't necessary. As it turned out, the evacuation and relocation worked well to protect both the national security and the Japanese-Americans themselves.

            It is easy to lose sight of the fact today, however, that the decision not to intern them was made at great risk. Experience during the war did demonstrate that there were a sizeable number of Japanese-Americans who militantly supported Japan. If they had conducted even one massive act of sabotage, would the risk have been worth it? How many lives, say, was the risk worth? 100? 1,000? 10,000? Whose lives?

The criticism of an inference

            After the war began, authorities anticipated acts of sabotage on the West Coast--but none occurred. Why? The critics of the evacuation argue that this is evidence that there were no disloyal persons of Japanese ancestry. A number of American officials at the time, however, including Earl Warren, drew diametrically the opposite inference: that there must be some who were willing to commit sabotage, but that for some reason they were being held back rather than being exposed.73 Warren and the others, including the columnist Walter Lippmann, considered it an ominous sign.74

            This inference was later ridiculed -- in fact, called "vicious" and unprofessional -- by the Congressional Commission on Wartime Relocation.75 Each reader should be able to decide for himself whether the reasoning was flawed (and, for those who agree with the critics who say that it was, whether it can appropriately be characterized as vicious).

A critically important choice: Mass evacuation or a case-by-case loyalty determination

            The normal course of law in a legal system that respects individual rights looks at the guilt of individuals, providing each "due process." The critics of the evacuation invoke this as the ground for a bitter denunciation of American policy, since the policy treated the Japanese-Americans as a group.

            The critical view would follow almost naturally from a position that acknowledges virtually no need for protective measures in the emergency: If the threat were slight, it would hardly outweigh the important value to be given to individual due process. We have already seen, however, that there was a vital need for immediate action.

            The critical view would also be reasonable if the American government had had an expeditious way to determine, by investigation and hearings, the loyalty of each person on an individual basis. But this was a virtual impossibility, given the cultural insularity of the Japanese-American community. (To make any practical sense, it presupposes that many of the Japanese-Americans would have come forward in hearings as witnesses against other Japanese-Americans; but we have seen the internal pressures, including murderous beatings, that the pro- Japan element could have brought to bear against it.)

            When the war was within months of being over, Supreme Court Justice Murphy found it easy to embrace the contrary view,76 but in the first case to come before the Court he had said that "the military authorities could reasonably have concluded at the time that determinations as to the loyalty of individual... persons of Japanese extraction on the West Coast could not be made without delay that might have had tragic consequences."77 Chief Justice Stone, writing for the Court, agreed, observing that "we cannot say that the war-making branches of the Government did not have ground for believing that in a critical hour such persons could not readily be isolated and separately dealt with."78 Justice Jackson, for his part, made a curious bifurcation reminiscent of Pontius Pilate's washing of his hands: that courts should continue even during wartime to hold to individual due process, but that they shouldn't interfere with the military if it found it necessary to do so.79

Why wasn't the same done with the Hawaiian Japanese-Americans?

            The point is sometimes made that the evacuation from the West Coast was inconsistent with having left the Japanese-American population on Hawaii. The answer is that with the declaration of martial law and the suspension of the writ of habeas corpus in December 1941, Hawaii was placed under direct military control. It is said to have been "governed like a military camp for all its inhabitants." This was not done on the mainland.80

Why weren't Americans of German and Italian extraction evacuated?

            Another point of criticism asks why the Japanese-Americans were evacuated but people of German and Italian ancestry were not. This has a double edge: it suggests that the evacuation really wasn't necessary; and it suggests that the evacuation was racially motivated.

            Senator Hayakawa wrote that "the answer is obvious. Germans and Italians, having come to America earlier than the Japanese and in far greater numbers, were already well-known to Americans in 1941."81 The same point was expressed in a letter that the city officials of Madera, California, wrote to then-attorney general Earl Warren in early 1942: "The general feeling about the Italians is that they are well assimilated, and we do not regard even the Italian aliens alien in fact...So far as we know, there are no German aliens in this community."82 The distinction lies in the vast difference in assimilation. The Germans and Italians had long-since become mixed with the general population.

Whether the exclusion should have been ended sooner

            In their late-1944 opinions, the Supreme Court justices were especially sensitive to whether the exclusion order should have been rescinded once the tide of military fortune shifted in favor of the United States. (The various concurring and dissenting opinions would, in fact, make an excellent case study in the vagaries of the liberal mind, since a certain ideological sentimentality became apparent once the improving war situation allowed it.) As it was, the order was rescinded as of January 2, 1945, when there were still more than seven months of warfare remaining with Japan. The argument is that it is unconstitutional to constrain an American citizen even a day longer than necessity requires, and that as time went on many of the Japanese-Americans were clearly known to be loyal.

            If it is agreed, however, that a group evacuation and resettlement was justified, it becomes a neat matter of timing as to when precisely the program should have been abandoned. The Roosevelt administration did not wait until the end of the war, but simply took longer than the critics assert it should have.

            We have seen that beginning in early 1944 "certificates of exemption" were granted to some to return to the West Coast. What is important, though, is to remind ourselves that the country was very largely occupied with other tasks. It shouldn't be necessary to recite the vastly complicated preoccupations that held Americans' attention in 1943 and 1944. Meanwhile, the relocation of many of the Japanese-Americans to eastern and mid- western communities was going on apace. While it is technically arguable that the exclusion order should have been rescinded earlier, the failure to do so is understandable.

Was the relocation a product of "racism"?

            Much public opinion on the West Coast had long been hostile to Japanese and other Asian immigration. Organized labor was for many years prominent among its opponents. And there is no question but that public opinion was inflamed against the Japanese during World War II, especially immediately following Pearl Harbor. This feeling was most intense on the West Coast, for a very specific reason: the National Guard units from eleven western states were fighting in the Philippines, where they were tortured and starved by their Japanese captors. Their families and friends felt passionately about these atrocities.83

            Throughout the war, one of the motivating factors in the policy of evacuation and resettlement was to protect the Japanese-Americans from public anger. It is easy today to say that that anger was "racist," but we have reason to be suspicious of attitudes taken under much more comfortable circumstances forty and even fifty years after the fact. To argue that the anger was vicious has, itself, a certain vicious quality about it.

            There were ample reasons for the evacuation that had nothing to do with racism. Justice Black wrote level-headedly about this in 1944: "To cast this case into outlines of racial prejudice, without reference to the real military dangers which were present, merely confuses the issue. Korematsu was not excluded from the Military Area because of hostility to him or his race...He was excluded because we are at war with the Japanese Empire...."84

            Justice Stone discussed whether there are occasions when national origin can be considered in making policy: "Because racial discriminations are in most circumstances irrelevant and therefore prohibited, it by no means follows that, in dealing with the perils of war, Congress and the Executive are wholly precluded from taking into account those facts and circumstances which are relevant...and which may in fact place citizens of one ancestry in a different category from others."85


            The matter came before the U. S. Supreme Court in three cases: Hirabayashi v. United States, 320 U.S. 81 (1943); Korematsu v. United States, 323 U.S. 214 (1944); and Ex Parte Endo, 323 U.S. 283 (1944). In the course of this discussion I have quoted much of the thinking expressed in those decisions.

            Hearings were held by the House of Representatives' "Select Committee Investigating National Defense Migration" (the "Tolan Committee") in February and March of 1942.

            In 1948 Congress passed the "Japanese American Evacuation Claims Act" under which approximately $38 million was paid to evacuees for property losses (though extensive measures had been taken by the Army and the War Relocation Authority to store and safeguard their property during the war). Critics later argued that additional money should have been paid for loss of earnings and for intangible damages such as "stigma" and "psychological impact."86

            In the late 1960s, a movement called "the redress movement" got underway.87

            Reflecting the pressure from that movement, President Gerald Ford issued a proclamation in 1976 saying that "we know now what we should have known then: not only was [the] evacuation wrong, but Japanese-Americans were and are loyal Americans."88

            In 1980 Congress created the "Commission on Wartime Relocation and Internment of Civilians." It issued its report, entitled "Personal Justice Denied," on February 22, 1983. John J. McCloy later wrote that "the manner and the atmosphere in which the hearings were held was outrageous and a disgrace."89 He said that "I have been before this Congress many times in hearings, but I have never been subjected to the indignities that I was at the hearings of the Relocation Commission. Every time I tried to say anything in favor of the United States or in favor of the President of the United States, there were hisses and boos and stomping of feet."90 David F. Trask, the chief historian for the U.S. Army Center of Military History, sees the Report as in effect an advocacy brief "to present the case against the Government in the most favorable light...Facts and arguments that might tend to support a contrary conclusion are either excluded or rejected."91 We have seen how it totally overlooked the existence of MAGIC, the decoded Japanese dispatches, which is a key to understanding why the Roosevelt administration took the action it did.92

            In 1984 hearings were held by the House Subcommittee on Administrative Law and Governmental Relations.

            In 1988 Congress passed the "Japanese Money Bill" under which more than $20,000 was paid, with an apology, to more than 60,000 of the evacuees.93 Even if someone accepts the notions that the evacuation was unjust and that compensation for "mental suffering" was called for, the provisions of this enactment are outrageous, since the recipients include:94

. 490 people who have long-since gone to live in Japan and who are citizens there.95 (American taxpayers will be interested in knowing that the very first checks were sent to these.)

. 6,000 people who were born in the relocation centers, and who can hardly be said to have undergone "mental suffering."

. The 4,300 individuals who attended American universities during the war.

. 1,370 enemy aliens whom the FBI interned in Department of Justice Internment Camps (something very different from the relocation centers) at the beginning of the war for distinct security reasons.

. 3,500 Japanese-Americans who renounced their ties to this country and asked to be sent to Japan.

. One hundred and sixty people who while in the camps belonged to the militantly pro-Japanese Black Dragon Society.

The long-term effect on the Japanese-Americans

            Although it has nothing to do with the merits of the evacuation, it is worth mentioning that the long-term effects on the Nisei and succeeding generations have almost certainly been beneficial. Senator Hayakawa wrote that "as one talks with Nisei today, one gets the impression that the wartime relocation, despite the injustices and economic losses suffered, was perhaps the best thing that could have happened to the Japanese-Americans on the West Coast. As many say, the relocation forced them out of their segregated existence to discover the rest of America...The relocation thus resulted in the Americanization of the Japanese in one generation after immigration--a record for non-English-speaking immigrants of any color."96


            The circumstances during World War II were much more complicated than those who would damn the United States as having "viciously set up concentration camps for the Japanese-Americans" ever admit. My study of the subject has persuaded me that Americans have nothing to be ashamed of about this episode, even though it is regrettable that war and its incidents ever have to happen.

            We should, however, be ashamed of the way in which we as a people have wallowed in self-abasement in our eagerness to be "generous" and "sensitive" in response to the bitter censures of alienated ideology. Most Americans I have talked with are thoroughly uninformed as to what actually happened and why, and yet are eager to join in the condemnation of the actions of the United States. 



1. Hearings before the Subcommittee on Administrative Law and Governmental Relations of the Committee on the Judiciary, U. S. House of Representatives, June 20, 21, 27 and Sept. 12, 1984 ["1984 Hearings"], testimony of John J. McCloy, p. 125; Roger Daniels et. al., editors, Japanese Americans: From Relocation to Redress (Salt Lake City: University of Utah Press, 1986), 140; Lillian Baker, Dishonoring America: The Collective Guilt of American Japanese (Medford, OR: Webb Research Group, 1988), 60.

2. 1984 Hearings, 579, testimony of Dr. Ken Masugi.

3. Report of the Commission on Wartime Relocation and Internment of Civilians, Personal Justice Denied (Washington: Government Printing Office, 1982), 9, 69, 99.

4. See the historical discussion in the first pages of Personal Justice Denied.

5. Dillon S. Myer, Uprooted Americans (Tucson: University of Arizona Press, 1971), 293; Daniels, Redress, 52.

6. Lillian Baker, American and Japanese Relocation in World War II: Fact, Fiction & Fallacy (Medford, OR: Webb Research Group, 1990), 22.

7. Testimony of Karl R. Bendetsen before the Commission on Wartime Relocation and Internment of Civilians, July 8, 1981, typescript available from National Archives, 140.

8. Ibid.

9. Baker, Fact, 65.

10. Bendetsen testimony, 10, 74.

11. Personal Justice, 145.

12. Bendetsen 1981 testimony, 20.

13. Personal Justice, 149.

14. Ibid.

15. S. I. Hayakawa, Through the Communication Barrier (New York: Harper & Row, Publishers, 1979), 132.

16. 1984 Hearings, Bendetsen testimony, 691.

17. Personal Justice, 136.

18. Myer, Uprooted Americans, 55.

19. Ibid., 48, 51, 56, 57.

20. Daniels, Redress, 61.

21. Personal Justice, 162.

22.Ibid.; Myer, Uprooted Americans, 48, 56-7.

23. Daniels, Redress, 48-9.

24. Personal Justice, 145.

25. Ibid., 181.

26. Daniels, Redress, 43.

27. Myer, Uprooted Americans, 91.

28. Hayakawa, Communication Barrier, 132.

29. Personal Justice, 203.

30. Ibid., 205.

31. Bendetsen 1981 testimony, 27-8.

32. 1984 Hearings, Bendetsen testimony, 682.

33. Baker, Fact, 52.

34. Daniels, Redress, 188.

35. Hayakawa, Communication Barrier, 134.

36. Ibid., 133.

37. Ibid., 132.

38. 1984 Hearings, Bendetsen testimony, 698.

39. Bendetsen 1981 testimony, 71.

40. 1984 Hearings, Bendetsen testimony, 686.

41. Bendetsen 1981 testimony, 61.

42. 1984 Hearings, Bendetsen testimony, 683.

43.See historical summary by Justice Stone, Hirabayashi v. U.S., 320 U.S. 81 (1943), 94.

44. Wichita Eagle, Feb. 23, 1992 (article noting 50th anniversary of attack); Myer, Uprooted Americans, 24.

45. Ibid.

46. Bendetsen 1981 testimony, 102.

47. Personal Justice, 5.

48. Hearings of the Select Committee Investigating National Defense Migration, House of Representatives, ["Tolan Committee Hearings"], Feb.-Mar. 1942, 10996.

49. Tolan Committee Hearings, 10997.

50. Ibid., 11107.

51. Ibid., 10973.

52. 1984 Hearings, testimony of David Lowman, 437.

53. Ibid., 438.

54. Personal Justice, 3.

55. 1984 Hearings, Lowman testimony, 431, 434.

56. Ibid., 437.

57. Ibid., testimony of John J. McCloy, 148.

58. Ibid., 120.

59. Hirabayashi, 96, 97.

60. Hayakawa, Communication Barrier, 135.

61. Baker, Fact, 35.

62. 1984 Hearings, testimony of Col. Frederick Bernays Wiener, 703.

63. Personal Justice, 251, 252.

64. Myer, Uprooted Americans, 63.

65. Ibid., 61.

66. Personal Justice, 178.

67. Ibid.

68. Ibid., 179.

69. Ibid., 248; Baker, Fact, 25.

70. Daniels, Redress, 63.

71. Bendetsen 1981 testimony, 18.

72. 1984 Hearings, Lowman testimony, 474.

73. Tolan Committee Hearings, testimony of Earl Warren, 11011.

74. Myer, Uprooted Americans, 22.

75. Personal Justice, 82.

76. Korematsu v. U.S., 323 U.S. 214, 236 (1944).

77. Hirabayashi, 112, 113.

78. Hirabayashi, 99.

79. Korematsu, 235.

80. 1984 Hearings, Masugi testimony, 583.

81. Hayakawa, Communication Barrier, 135.

82. Tolan Committee Hearings, Warren testimony, 10995.

83. 1984 Hearings, Bendetsen testimony, 683.

84. Korematsu, 223.

85. Hirabayashi, 100.

86. Personal Justice, 4, 12.

87. Daniels, Redress, 188.

88. Ibid., 5.

89. Daniels, Redress, 213-14.

90. 1984 Hearings, McCloy testimony, 125.

91. Ibid., testimony of David Trask, 79.

92. Ibid., McCloy testimony, 131; Ibid., Lowman testimony, 435.

93.Wall Street Journal, Sept. 10, 1991, letter from William J. Hopwood.

94. Wall Street Journal, Hopwood letter.

95. Baker, Fact, 110.

96. Hayakawa, Communication Barrier, 135.