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Liberty Suspended- T h e I n t e r n m e n t o f 1 1 0 , 0 0 0 A m e r i c a n s -
Anna Caruso, Boyea, Bl. 3, 2012
“Only What We Could Carry Was the Rule, So We Carried Strength, Dignity, and Soul.”1
War is a word that evokes fear. Images of bloody battles, farewells to family and
friends, and long, uncertain days inundate us. It is believed that war is fought to maintain
good- to fight aggressive forces that threaten to overthrow a delicate balance of peace we
have tirelessly worked to maintain. While soldiers fight on the front line, we, at home,
feel required to fight equally as hard. When we feel our kin, careers, and personal
liberties are threatened, there is no question why it is all too easy to forget the rights of
others. War is a selfish time. Prioritizing self-interest over the interest of others during
war dates back to our nation’s beginnings. The French Revolution menaced the newly
woven coalition of states- who was a supporter? Who was not? John Adams, second
president to the republic, felt uneasy about the French Revolution.2 Thus, he passed the
controversial Alien and Sedition Acts in a dual attempt to stifle pro-French
demonstrations and lessen the risk of spies in the country.3 This trend of suspension of
liberties continued into the following century during the Civil War. Even Abraham
Lincoln, often considered one of the most illustrious American presidents, succumbed to
the war hysteria and twice suspended the writ of habeas corpus.4 World War I saw it’s
fair share of civil atrocities with unwarranted raids against Russian-Americans as a
product of the widespread Red Scare.5 Unfortunately, it has not been hard to find these
examples of government hypocrisy against it’s own constitution. These times of war
make uncalled for actions fearfully easy. Hopefully, knowing this, survivors of Japanese
Internment will take their expulsion less personally.
It is seldom seen for a weak man to challenge a stronger man to fight. Likewise,
one rarely sees a powerful and influential group ignored, especially in the political
sphere. An explanation for the lack of empathy for Asian Americans can be traced back
to the arrival of the Chinese in the 1860s.6 These laborers came in large waves, and posed
a threat to the job security the white Americans felt they were entitled to. These laborers
who demanded little pay and could supply many men to a site were soon targeted as
nuisances stealing money away from the “true” Americans.7 These new immigrants, who
looked, acted, and spoke different from the white Europeans the Americans were
accustomed to, were, not unexpectedly, lumped together and discriminated against as a
whole. In 1905, a racism-driven league called the Asiatic Exclusion League was formed
in California by nativists who were put off by the perceived invasion of unsavory
foreigners.8 Further, tensions arose with Japan regarding the unrest ‘caused’ by Japanese
immigrants, leading to the signing of the Gentleman’s Agreement- an agreement by
Japan to not send any more emigrants in exchange for better treatment of the ones already
residing in the United States.9 It’s a solemn thought that treaties were once seen as
acceptable methods to resolve the conflicts amongst special interests- even worse that
they were expected to be effective. These failures of compromise and reason continue to
be lackluster moments in our history.
Unsurprisingly, the agreements made attempting to resolve conflict didn’t work;
the tensions remained, and were only exacerbated by the commencement of World War
II. This war, worse than any large scale international conflict had ever been,
foreshadowed long and bloody fights for all parties. America felt shockwaves ripple
across the vast country when Japan launched an attack on a base in Hawaii known as
Pearl Harbor. During this two-wave air strike, hundreds of Japanese aircrafts attacked the
base, which served as the headquarters for the American Pacific Fleet.10 Over 2,000
Americans were killed and more wounded in the attack, with the Japanese suffering much
fewer casualties.11Despite the hefty legacy Pearl Harbor is often honored with, the reality
is different. While the Japanese did kill many American civilians, they destroyed mostly
unused aircraft and sank a handful of aged battleships.12 Their main offense was an injury
to American pride. Above anything else, Americans were outraged and determined to
avenge this attack- the Japanese Americans were to pay a heavy toll for the actions of the
Japanese military. On February 19th, 1942, President Franklin D. Roosevelt signed
Executive Order 9066- an evacuation order forcing all Japanese Americans living on the
West Coast into camps spanning the region.13 This order shocked Japanese Americans.
They knew, as did all other citizens, that this time of war would indeed lead to
unprecedented measures, only, until then, no one expected America’s rifles to point
inwards.
America was a nation founded upon principles of freedom, democracy, and
liberty. Wars, spanning centuries of conflict and hardship, were fought to preserve these
virtues. World War II, arguably, was fought for the same reason. It is ironic, then, that
during such a time, a country who claimed to be fighting the enemy to preserve peace and
tranquility at home, would take the opportunity to violate a minority group under the
guise of ‘wartime procedure.’ Executive Order 9066 unconstitutionally and unjustly
removed over 100,000 American citizens from their homes, communities, jobs, and
friends. This order destroyed lives, careers, but, most unfortunately, crushed the spirit and
good faith of this blossoming community of immigrants and new Americans.
Government hypocrisy, the deplorable conditions of the evacuation camps, and the
unjustifiable long-term effects of this atrocity highlight this event in American history as
one of the most notable and regrettable violations of civil liberties.
Good judgment is a critical component of an effective government, and while this
aspect of America’s government was clearly compromised during this era, the blatant
hypocrisy committed by it was inexcusable. Facets of our nation- basic and natural rights-
were overlooked, and swept under the carpet in order to give the government the room to
do as it pleased in regards to the Japanese Americans. Most obvious of the offenses were
the evident violations of key constitutional amendments- the 5th and 14th amendments.
The fifth amendment’s origins are deeply embedded in our history, when Anti-Federalists
refused to support the constitution, unless it had stipulations upon which the government
could not become too powerful so that it took away the rights of the citizens.14 The Fifth
Amendment explicitly states, “No person shall be held...for a…crime…without due
process of law.”15 This would go to say that no American could be punished unless they
are formally accused of a crime, and are led through all the steps in the conviction of the
said crime. For all the Japanese evacuated, this was clearly not the case. With Executive
Order 9066, the United States suspended due process, rounded up over 100,000 Japanese
Americans, and exiled them to desolate deserts in the west. They were accused of no
crime, except the fact that they were Japanese.16 Most found out about their coming
removal by fliers posted around the west, as well as through radio broadcasts. As if this
betrayal by the country immigrants had come to was not enough, what’s worse, is that the
majority of those affected by this order were native-born Americans. The 14th
amendment, added following the Civil War in order to further define citizenship for the
African American slaves, still held true for all people born in the United States of
America- one is a citizen by birth. Similar to the 5th amendment, the fourteenth
amendment guaranteed certain freedoms, stating, “No state shall…deprive any person of
life, liberty…nor deny to any person…equal protection of the laws.”17 The 14th
amendment is highly relevant to the internment of the Japanese because it highlights one
of the most glaring errors of Executive Order 9066: the failure to differentiate between
the Nisei and Issei, or, 2nd and 1st generation Americans.18 If any argument could be made
for internment, it could be that the Issei would be more likely to have pro-Japanese
tendencies, and thus could potentially prove a threat. But, regardless, this would not be
the case, as both immigrants and those who had been born and raised American were
lumped all under the category of ‘subversives.’ The overt and hypocritical suspension of
these two all-important statutes for the Japanese Americans further proves how the
American government was overstepping its boundaries, and taking actions that it found
most convenient, disregarding morals and integrity in the process.
Court cases pertaining to Japanese Internment shine light on the concerning fact
that not only was the executive branch not fairly assessing the situation, but neither was
the judiciary. Numerous cases arose in which the Supreme Court could’ve taken the
initiative to concede that executive order 9066 was unconstitutional, yet it failed
repeatedly. One of the most famous cases was that of Fred Korematsu. Korematsu was
born in California in 1919 to Issei parents, and grew up living a standard American life.19
When the executive order was issued, Korematsu refused to go into his assigned
relocation center, and evaded evacuation for sometime until he was spotted in San
Leandro using an alias, and sentenced to probation.20 He brought his case to the Supreme
Court in 1944, but, in a 6-3 decision, the court upheld the government’s decision to hold
Japanese Americans in the evacuation camps in the west, on the grounds that it was part
of a necessary agenda put in place to protect the collective good of the country.21 It would
not be for another thirty-eight years that Fred Korematsu’s case would be appealed, on
the basis that he had not received a fair trial, because the government and its lawyers had
concealed important information and documents.22 Other cases received equally unfair
handling, such as the case of Hirabayashi v. United States, a case that affirmed the
legality of curfews imposed on the Japanese Americans as a congressional right.23 These
two cases were profound testaments to the inherent racism of the time. Justice Frank
Murphy famously dubbed them “legalization of racism.”24 Shockingly, even though FBI
and Office of Naval Investigation both concluded that Japanese Americans had not
partaken in acts of sabotage, these findings were withheld from the court.25
Unfortunately, the Supreme Court, at this important time in history, proved itself
ineffectual in its most basic of duties- to protect the constitution and those it was created
to defend.
It is a widely accepted fact that had the Japanese not bombed Pearl Harbor; the
internment camps would not have been put into effect by the United States government.
This idea then only begs the question, “What if there had been no Pearl Harbor?” In
reality, this question is of high importance. In a further demonstration of the crooked
government at this time, the infamous McCollum Memo hints that there was a great
possibility that had America not aggressed Japan, Pearl Harbor would not have been
bombed, and the Japanese Americans would thus not have been incarcerated. Therefore,
it is not an unreasonable argument to pin the evacuation wholly on the American
government itself. On October 7, 1940, Lieutenant Arthur McCollum of the Office of
Naval Intelligence sent a memo to Captains Walter Anderson and Dudley Knox- two of
President Roosevelt’s most trusted military advisors.26 The memo contained a detail
eight-step plan by which America could antagonize Japan into attacking the United
States.27 In the then-classified document, McCollum states, “If by these means Japan
could be led to commit an overt act of war, so much the better.”28 They were correct: after
the 8th provocation1 (an embargo of all U.S. trade with Japan, as well as a similar
embargo imposed by the United Kingdom) Japan attacked Pearl Harbor.29 While the
1 The other provocations mostly included uniting with Holland and Great Britain in order to antagonize Japan, and sending fleets into Asia.
public was told that this event was a complete surprise, an American government mission
had been accomplished, and America entered World War II.30 This memo, while a totally
legitimate document for a Lieutenant to be sending, was really the root of the issue that
led to the Japanese internment camps. Perhaps had the American government not goaded
Japan into committing such an act, hundreds of thousands of people would’ve been
spared the emotion obstacles that were to face them as a result.
Civil liberties cannot be so narrowly defined to be only what is legal and signed
to paper- they are a great deal more, and the Japanese Americans were not graced with
any during the years prior to their internment. Civil liberties entitle every person respect.
Treated as criminals for a war operation they had no connection to, the Japanese
Americans lost their homes, businesses, jobs, personal possessions, and money. Adding
insult to injury was the fact that any other American citizen could remain in his or her
home unless tried and convicted of espionage-any American citizen that wasn’t of
Japanese descent, that is. The Nisei were removed forcibly from their homes without any
solid evidence to their guilt.31 A disturbing fact about this time in which the Japanese
were being notified of their impending relocation was that few politicians protested the
measures. Most openly supported it in order to maintain the support for their constituents,
who consisted of mostly white Americans who had little sentimental attachment to the
people that were about to be sent away. While they represented a small percentage of the
population, Japanese Americans on the West Coast had long been special targets of white
hostility.32 Laws and regulations excluded Japanese Americans from full participation in
several sectors of society decades. Issei could not own land, eat in certain restaurants, or
become naturalized citizens. American-born descendants of Japanese immigrants were
citizens by birthright, and many had become successful in business and farming. The
attack on Pearl Harbor gave whites a chance to renew their hostility toward their Japanese
neighbors.33 A white Californian man working in the farming business openly voiced is
distaste for the Japanese, saying, “If all of the Japs were removed tomorrow, we’d never
miss them… because the white farmers can take over and produce everything the Jap
grows. And we don’t want them back when the war ends, either.”34A congressman from
California once shouted, “The only good Jap is a dead Jap!”35 Even the state’s attorney
general, Earl Warren, said, “When we are dealing with the Caucasian race, we have
methods that will test loyalty…but…with the Japanese, we are in an entirely different
field…”36 Such ignorance at such a high level is frightening, and such open expressions
of prejudice would never pass today in the government. Too many Americans were
enthusiastic at the prospect of the Japanese Americans leaving, for their departure would
relive farmers and small business owners of what had previously been serious
competition.37 Additionally, Japanese Americans facing internment were forced to
liquidate their assets and endure watching white Americans pay pennies on the dollar for
their possessions before leaving for the camps.38 This was an extremely trying time
emotionally for the Japanese Americans, who were alienated and rebuffed in their own
homeland. In her memoir, Looking Like The Enemy, Mary Matsuda documents the
emotions she felt during this time. She laments, “I felt guilty, ashamed…every time
anyone looked at me I imagined hatred in their eyes. In one of my classes, I began to cry
as much from confusion as frustration.”39 Further, she explores the identity confusion
many Japanese American children and teens had. Matsuda recalls thinking, “I am an
American, yet I don’t look like one.”40 While not an explicit law, to feel so cast aside and
neglected in one’s own country is in itself a great violation of civil liberty, and it was the
reality for over 100,000 Americans then.
Aside from the cold treatment they had received all their years as American
immigrants and citizens, nothing could have prepared the Japanese Americans for the
deplorable conditions they would come to face during their sentences in the internment
camps. Upon hearing the evacuation order, the Japanese Americans knew their situation
was about to fall to an unprecedented low. Watching the lives they had worked decades
to built be destroyed left such an impact that few knew of the difficulties to come. The
transportation to the camps was a traumatizing experience for many. Young children who
didn’t speak English were herded, like cattle, with their families onto trucks for
transportation to the centers.41 Once they arrived, the conditions were shocking. Located
in the sweltering deserts through which gale winds and dust storms often passed, these
camps contained makeshift barracks, and primitive communal sanitary facilities all
enclosed with barbed wire fences, guarded by armed men.42 In some cases, families were
separated and put into different camps. These relocations spurred changes that forced
acclimation and toleration to deprivation of personal and family privacy.43 The famous
expression “only what we could carry” describes what possessions the internees could
bring to the camps, all of which was searched and inspected on arrival. My great-
grandfather had absent mindedly packed his razor before leaving his home in Pasadena,
California, and as my grandmother recounts, had “a lot of explaining to do” when it was
uncovered.44 Conditions were so bleak that even the president himself referred to the
centers as “concentration camps.”45 Food was served from a communal cafeteria on
camp, yet hardly provided adequate nutrition for those interned. Yuriko Otani, my
grandmother, was interned at Tulare as a young teenager, and experienced all the
hardships the Japanese Americans encountered. She recalls, “The months at Tulare made
us all ill from the contaminated water and heat…I could not consume the food, and at age
11, only weighed 68 pounds.”46 Living quarters in the camps were cramped and
impersonal. Often, the barracks were larger structures (in some cases, as crude as horse
stalls) partitioned to fit as many families as possible.47 As a result, disease and illness
spread like wildfire.48 While not highly publicized, many internees did die as a result of
their incarceration. Causes ranged from insufficient medical care, emotional distress, and
bullets from the camp guards who could shoot any ‘unruly’ internee.49 Yet, amazingly,
despite these conditions, the Japanese Americans proved resilient and strong. Every
dawn, they awakened to salute the flag and proceed to their on-site jobs, all as a testament
to their loyalty. Most signed official loyalty oaths as well.50 Otani reflects, “I am amazed
that the people had aspirations for activities such as crafts, music, drama, religion, sports,
and education…the camp was functioning with dignity.”51 Yoshiko Uchida, an internee,
remembers how the “Issei tried wholeheartedly to make the best of deplorable
conditions…maintaining the values and faith that had sustained them thus far became
ever more important.”52 Others were inspired too. Ansel Adams, legendary American
photographer, documented the strength and solidarity of the Japanese Americans interned
at the Manzanar camp; the only time he ever documented people.53 The way that the
Japanese Americans were able to rise above such adversity in the camps is truly
remarkable, yet the fact remains that these camps were inhumane and unacceptable for
innocent people, and should never have come to existence in the first place.
While the ordeals for the Japanese Americans before and during internment were
treacherous, some of the aftermath of their situation has proved to be even more
frightening. Numerous studies have shown the deadly effects the camps had on their
survivors. Rates of suicide were twice as high among interned Japanese Americans than
in those who never endured the years of incarceration.54 Other long-term effects such as a
doubled risk of cardiovascular disease and a life shortened by 1.6 years were also
discovered.55 It isn’t surprising to see these kinds of statistics among people who suffered
through a traumatic experience such as the internment camps. More recently,
Posttraumatic Stress Disorder, or, PTSD, has made headlines as its frequency has
increased over the past couple of years. It is not unlikely that many of the camp survivors
were victim to this illness, and that it played some kind of role in their adverse health
later in life.56 It took a while for the government to own up to its actions, but in 1988,
Congress passed a bill formally apologizing to the Japanese Americans for their
incarceration during World War II.57 The bill provided for $20,000 to each surviving
internee in the hopes that, in some way, it could help make up for their ordeal. While this
could never make up for all that the camps destroyed, the government’s admittance of its
error was crucial in helping assure the survivors, advocates of civil liberties, and the
young Americans of today that such an atrocity would hopefully never be executed again.
The evacuation, incarceration, and degradation of over 110,000 Japanese
Americans during World War II was arguably the biggest civil rights violation in
American history. It was allowed to happen by several unacceptable factors, major ones
being racism, war hysteria, and lack of proper judgment. The years in camps proved to be
some of the most trying years of the internees’ lives, yet also ones in which a new spirit
of hard work and perseverance was born into the Japanese American community- one
that to this day remains. Undeniably, everyone learned a positive lesson in some way or
another from this. Historically, America has been too ready to accept presidential
decisions as correct, simply because we are in a state of war.58 During the senate hearings
regarding John Roberts’s nomination as chief justice, the issue of Japanese Internment
was rehashed. Would this decision we upheld today? Roberts’s said, emphatically, that he
would “be surprised if there were any arguments that could support it.”59 Evidently, with
time, government officials have gained wisdom regarding such a monumental decision
and its monumental drawbacks. The statement that undeniably summarizes this entire
problem that has been eating away at many for so long was made by Justice O’Connor,
who articulated, “A state of war is not a blank check for the president when it comes to
the rights of the nation’s citizens.”60 This idea is ever more important as our world shifts
to a place where war is more frequent, and racism still too rampant. America still has the
potential to be the land of opportunity, the land in which the rights of citizens are meant
to go before those of the government, but this can only be achieved if the government
works tirelessly to ensure these fundamentals aren’t forgotten in the midst of
modernization. Norman Y. Mineta, a survivor of internment, once wrote, “We as
Americans place great trust in…our constitution. The constitution is not a document of
perfection, however. It is a license to pursue a ‘more perfect union’…it is a document
that is only as expert in protecting us as we are determined to protect it.”61 Mineta is
correct: as long as we are devoted to protecting the constitution, America will be a place
where we are all secure, knowing our freedoms cannot and will not be compromised.
Minorities in America have always struggled, and there is no doubt that this will
always be the case. However, as with the Japanese, certain groups come under
particularly harsh criticism as a result of the acts of a few of their nationality. 9/11
marked a scary time for Americans of all creeds and colors. Not unexpectedly, Islam
soon became the face of terror, the face of war on American freedom. While it has been
difficult to study Muslim Americans as censuses do not ask for religious affiliation, a
survey conducted in 2011 found that the majority of Muslim Americans felt life was
more difficult after 9/11, being the subjects of offensive names, and regularly singled out
at airline security checkpoints.62 This level of distress mirrors that of the Japanese
Americans following Pearl Harbor. It is a feeling that no one deserves, especially not in
times like these or in a country like ours. It is an inherent right to feel safe and secure,
and while some may feel targeting those ‘close’ to the enemy is ensuring their own
safety, there is still no justification. Fred Korematsu saw the connection between his time
and ours- he feared that the Muslim Americans would fall victim to the same kind of
degradation as the Japanese. Korematsu became an outspoken critic of the racial profiling
of Arab-Americans in the wake of the 9/11 attacks.63 Hopefully, with more advocates like
Fred Korematsu, we can rest assured that discrimination of large ethnic groups will in
time fade away, hand in hand with the difficult memories of the past.
1 Lawson Fusao Inada, Only What We Could Carry (Berkeley: Heydey Books, 2002), xvii2 Bill Moyer, “Civil Liberties in War Time,” PBS, 17 July 2007, http://www.pbs.org/moyers/journal/07132007/civilliberties.html, (accessed 6 June 2012)3 ibid4 ibid5 ibid6 Victor Bondi, American Decades 1940-1949 (Gale, 1995), 2407 "Timeline of Asian American History." http://www.digitalhistory.uh.edu/asian_voices/asian_timeline.cfm (accessed May 23, 2012)8 ibid9 ibid10 Taylor, Maxine. "America Remembers the 70th Anniversary of Pearl Harbor: Overview." In World at War: Understanding Conflict and Society. ABC-CLIO, 2005-. Accessed May 18, 2012. http://worldatwar.abc-clio.com/.11 ibid12 Hedley P. Willmott and Michael Barrett. "World War II (Overview)." In World at War: Understanding Conflict and Society. ABC-CLIO, 2005-. Accessed May 18, 2012. http://worldatwar.abc-clio.com/.13 American History, s.v. "Franklin D. Roosevelt: Executive Order 9066 (1942)," accessed June 9, 2012. http://americanhistory.abc-clio.com/.14 American Government, s.v. “Bill of Rights (1791),” accessed May 21, 2012. http://americangovernment.abc-clio.com./15 ibid16 Inada, What We Could Carry, xi17 American Government, s.v. "Fourteenth Amendment (ratified 1868)," accessed May 21, 2012. http://americangovernment.abc-clio.com/.18 Van Riper, A. Bowdoin. History in Dispute, "Gale U.S. History in Context." Last modified 2000. Accessed May 25, 2012. http://ic.galegroup.com/ic/uhic/ReferenceDetailsPage/ReferenceDetailsWindow?displayGroupName=Reference&disableHighlighting=true&prodId=UHIC&action=e&windowstate=normal&catId=&documentId=GALE19 “Fred Korematsu Day,” TIME Magazine, Jan 20, 2011 (http://www.time.com/time/nation/article/0,8599,2045111,00.html)20 Bondi, Decades, 31821 Watts, Tim. "Fred Korematsu." In American History. ABC-CLIO, 2000-. Accessed June 9, 2012. http://americanhistory.abc-clio.com/.22 Bondi, Decades, 31823 Hirabayashi v. United States, http://academic.udayton.edu/race/02rights/intern01.htm#Hirabayashi24 Bondi, Decades, 24125 ibid26 The McCollum Memo: The Smoking Gun of Pearl Harbor, http://whatreallyhappened.com/WRHARTICLES/McCollum/index.html27 ibid28 "McCollum Memo." rationalrevolution.net - Making sense of history, economics, politics, philosophy, and war. http://www.rationalrevolution.net/war/mccollum.htm (accessed May 21, 2012).29 Smoking Gun30 ibid31 William H. Rehnquist, When The Laws Were Silent, http://www.americanheritage.com/content/when-laws-were-silent.
32 PBS, The War At Home, http://www.pbs.org/thewar/at_home_civil_rights_japanese_american.htm33 ibid34 ibid35 Bondi, Decades, 34236 ibid37 ibid, 24138 ibid, 30539 Mary Matsuda Gruenewald, Looking Like The Enemy, (Troutdale, OR, NewSage Press, 2005), 540 ibid41 Bondi, Decades, 34242 Yuriko Otani, “Date of Infamy Changed Lives Forever, “Pascack Valley Community Life, Dec. 7, 199143 ibid44 ibid45 PBS, Children of the Camps, http://w.org/childofcamp/history/index.html (accessed May 21, 2012).46 Otani, “Date of Infamy,”47 Bondi, Decades, 34248 Study of the Mind, Medical Treatments of Japanese Internment Camps, http://www.studyofthemind.com/medical-treatments-of-japanese-internment-camps/49 PBS, Children of the Camps50 Bondi, Decades, 24151 Otani, “Date of Infamy”52 Yoshiko Uchida, Desert Exile: The Uprooting of a Japanese American Family, (Washington, University of Washington Press, Oct 1, 1984), 14853 Bondi, Decades, 29654 Study of The Mind, Medical55 ibid56 ibid57 Bondi, Decades, 30658 Anthony Lewis, “License to Torture,” New York Times, Oct 15, 2005.59 ibid60 ibid61 Norman Y. Mineta, “A Test America Failed,” USA Today, Feb 18, 2008.62 Carol Morello, “Muslim Americans say life is more difficult since 9/11”, The Washington Post, August 30, 201163 Watts, Korematsu, American History
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• Woo Liu, Ling. "Fred Korematsu Day: California Honors a Civil Rights Hero - TIME." Breaking News, Analysis, Politics, Blogs, News Photos, Video, Tech Reviews - TIME.com. N.p., n.d. Web. 12 June 2012. <http://www.time.com/time/nation/article>
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