Korematsu v. United States||Case Summary|| 323 U.S. 214 1944|| Constitutionality of Japanese-American Internment

Constitutionality of Japanese-American Internment

FACTS

During World War II, President Franklin D. Roosevelt issued Executive Order 9066, which authorized the internment of Japanese-Americans in designated military zones. Fred Korematsu, a U.S. citizen of Japanese descent, refused to comply with the order and was arrested and convicted for remaining in a restricted area. Korematsu challenged the order, arguing that it violated his constitutional rights under the Fifth Amendment.

ISSUES

1. Did the internment of Japanese-Americans under Executive Order 9066 violate the Fifth Amendment’s guarantee of due process?

2. Was the racial classification used to justify the internment constitutional under the war powers of the U.S. government?

RELEVANT CONSTITUTIONAL PROVISIONS

Fifth Amendment: Protects against deprivation of life, liberty, or property without due process of law.

War Powers of Congress & the President: Allows the federal government to take extraordinary measures during wartime to ensure national security.

JUDGEMENT

The U.S. Supreme Court, in Korematsu v. United States in a 6-3 decision, upheld Korematsu’s conviction and ruled that the internment was constitutional. The majority, led by Justice Hugo Black, held that the need to protect national security during wartime outweighed Korematsu’s individual rights. The Court applied a form of strict scrutiny but justified the racial classification as a necessary wartime measure.

However, Justice Murphy and Justice Jackson dissented, condemning the decision as a violation of civil liberties and an endorsement of racial discrimination.

SIGNIFICANCE

The ruling established that racial classifications must meet the highest level of scrutiny but controversially upheld the internment as a “military necessity.”

It remains a widely criticized decision and was formally repudiated by the Supreme Court in Trump v. Hawaii (2018), which stated that Korematsu was wrongly decided.

In 1983, Korematsu’s conviction was overturned in a lower court, recognizing that the government had suppressed evidence undermining the justification for internment.

This case is a landmark in constitutional law, demonstrating the tension between civil liberties and national security during wartime.

Vinita Pathak