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date: 21 October 2019

The Movement for Japanese American Redress

Summary and Keywords

The Japanese American Redress Movement refers to the various efforts of Japanese Americans from the 1940s to the 1980s to obtain restitution for their removal and confinement during World War II. This included judicial and legislative campaigns at local, state, and federal levels for recognition of government wrongdoing and compensation for losses, both material and immaterial. The push for redress originated in the late 1940s as the Cold War opened up opportunities for Japanese Americans to demand concessions from the government. During the 1960s and 1970s, Japanese Americans began to connect the struggle for redress with anti-racist and anti-imperialist movements of the time. Despite their growing political divisions, Japanese Americans came together to launch several successful campaigns that laid the groundwork for redress. During the early 1980s, the government increased its involvement in redress by forming a congressional commission to conduct an official review of the World War II incarceration. The commission’s recommendations of monetary payments and an official apology paved the way for the passage of the Civil Liberties Act of 1988 and other redress actions. Beyond its legislative and judicial victories, the redress movement also created a space for collective healing and generated new forms of activism that continue into the present.

Keywords: Japanese American, World War II, incarceration, redress, Executive Order 9066, Civil Liberties Act

Introduction

In 1988, President Reagan signed into law the Civil Liberties Act, which authorized monetary payments and a formal apology for the World War II incarceration of Japanese Americans. The movement for Japanese American redress, which culminated with the passage of the Civil Liberties Act, originated just after World War II. During this period, the status of Japanese Americans in US society dramatically shifted. No longer members of a treacherous enemy race, Japanese Americans transformed into model citizens who had proven their loyalty through military service and economic self-sufficiency. The postwar rise of Japanese Americans became a potent symbol in the context of the Cold War and civil rights movement to show the credibility of US democracy and counter demands for state programs to alleviate poverty and racism. For Japanese Americans, these factors shaped the possibilities and limitations of turning to the government to obtain restitution for their wartime removal and confinement.

From Enemy Alien to Model Citizen: The Postwar Roots of Redress

Though the Japanese American redress movement brings to mind the legislative battles of the 1980s, the origins of redress stretch back to the postwar period. In the years following World War II, Japanese Americans transformed from enemy aliens to model citizens who had remained steadfastly loyal to the United States. The public image of Japanese Americans that formed during these years figured centrally in the recognition of the World War II incarceration as a mistake and laid the foundation for government support of redress actions, which began as early as 1948. It also enabled Japanese Americans to emphasize their patriotism and loyalty as a strategy for achieving legislative goals, even as it marginalized those who did not conform so easily to deserving victimhood.

This shift from enemy alien to model citizen occurred as a response to both domestic and international developments. On the domestic front, the War Relocation Authority (WRA), the governmental agency that oversaw the ten major camps, played a key role in the rehabilitation of Japanese Americans as model citizens. Though the notion of all Japanese Americans as a national security threat had justified mass removal and incarceration, the WRA approached the administration of the camps with a different mindset. Many in the WRA viewed the camps as an opportunity for Japanese Americans to shed their Japanese cultural influences and prepare for life in white mainstream society.1 Those who demonstrated good citizenship and loyalty to the United States would be rewarded with the opportunity to leave camp for work or education in the interior of the country. In 1943, the WRA formalized this process through the resettlement program.2 In order to successfully disperse Japanese Americans around the country, however, the WRA first needed to counter decades of propaganda that had portrayed Japanese Americans as enemy aliens and instead emphasize their Americanness. The WRA promoted its resettlement programs with a public relations campaign aimed at convincing a skeptical white public that Japanese Americans were just like them. Heavily staged photographs of Japanese Americans in everyday suburban settings circulated around the country, along with newspaper articles describing the success of Japanese American integration into white suburban life.3 Though these images did not reflect the lived experiences of those leaving the camps, they did contribute to a growing shift in the public representation of Japanese Americans.

A handful of critics and artists outside the government also took an interest in Japanese Americans and documented their experiences for public audiences. The work of Ansel Adams, landscape photographer and conservationist, became the most visible during this period because of his connection to the WRA. In 1943, Adams toured Manzanar at the request of camp director Ralph Merritt, an old friend from the Sierra Club, who wanted to promote a positive image of the camp after a tumultuous year that included widespread unrest among the imprisoned population and the death of two Japanese Americans shot by camp guards. In 1944, Adams published Born Free and Equal: The Story of Loyal Japanese-Americans, which contained dozens of photographs of Manzanar as well as commentary on the lives of his subjects.4 While not an official government publication, Born Free and Equal mirrored WRA objectives. Adams presented Japanese Americans as happy and industrious, unwavering in their support of the government and determined to carry on with their lives. There’s an “all-American” quality to Adam’s Manzanar photos, which showed Japanese Americans as normal, everyday people. By emphasizing their Americanness, Adams undermined the logic of mass incarceration that had deemed all Japanese Americans disloyal on the basis of race. Yet Adams did not critique the injustice of the incarceration as much as the injustice of incarcerating such a loyal and patriotic people.5 As the title conveys, Adams was critical of the incarceration, but only because he considered Japanese Americans undeserving of such harsh treatment. Though not a bestseller, Born Free and Equal did reach a public audience, unlike the work of his contemporary, Dorothea Lange, who captured the injustice of the incarceration with such force that the government removed her photographs from the public domain and impounded them for the duration of the war.6

Efforts by the WRA and others like Ansel Adams laid the representational groundwork for the postwar era in which the image of Japanese Americans as model citizens became more deeply entrenched. Following the end of World War II, the United States remade Japan as its ally in the fight against the Soviet Union and the spread of communism in Asia. The transformation of Japan from hated enemy to friend of the United States was carried out in the realm of both foreign policy and popular culture. As the US government pursued its national goals abroad, writers, filmmakers, and other cultural producers sought to rehabilitate the image of Japanese people for the American public. This included Hollywood films and bestselling novels that portrayed Japan as a submissive, feminized country through the trope of interracial romance, as well as magazine articles and news reports that featured the successful integration of war brides and other newcomers from Japan.7 Though not explicitly about the wartime incarceration, these cultural narratives deeply shaped the perception of Japanese people both at home and abroad, and contributed to the growing acceptance of Japanese Americans as legitimate citizens in the United States.

The context of the Cold War created an opening for Japanese Americans to rehabilitate themselves in the eyes of the American public. To counter the widespread belief in their inherent disloyalty, Japanese American leaders and organizations, led most notably by the Japanese American Citizens League (JACL), embarked on their own campaign to transform the image of Japanese people as loyal Americans who had never strayed from their love of the United States despite the great injustice done to them. While the JACL did not represent the views of all Japanese Americans, the organization gained outsized influence during the postwar period owing to its relationship with the federal government. During the war, the JACL had urged Japanese Americans to comply with the mass removal programs and had supported the military draft and other controversial measures implemented by government officials. After the war, the federal government continued to look to the JACL as the representative voice of the Japanese American community, thus amplifying the organization’s message and empowering its leadership.8 By the late 1940s, the JACL emerged as the most prominent Japanese American organization in the country, well positioned to begin demanding concessions from the federal government, starting with the Evacuation Claims Act of 1948.

Signed into law by President Truman, the Evacuation Claims Act provided $25 million in monetary compensation to Japanese Americans for losses sustained as the result of their “evacuation or exclusion” from the West Coast. Under the Evacuation Claims Act, Japanese Americans had eighteen months from the law’s enactment to file a claim for property losses of up to $2,500 per individual. Part of a broader push by Japanese Americans in the immediate postwar years for the dismantling of anti-Japanese restrictions, the Evacuation Claims Act was the brainchild of JACL leader Mike Masaoka who played a key role in the passage of the final bill.9 Masaoka emerged after the war as the most visible Japanese American leader in part because he framed his calls for equal citizenship as a reward for Japanese American devotion to the United States.10 As a political strategy, this was highly effective. That Masaoka was able to convince members of Congress to support a bill that would compensate Japanese Americans financially just three years after the war’s end speaks to how cannily he read the Cold War political landscape. And yet the political compromises required to pass the Evacuation Claims Act resulted in a watered-down bill that did very little to help Japanese Americans. The program itself was hampered by so much bureaucratic red tape that few Japanese Americans even attempted to file claims. By 1965, when the final claim was settled, Japanese Americans had received back less than ten cents per dollar lost during the war.11

Though from a practical standpoint the Evacuation Claims Act was a huge disappointment to Japanese Americans, it did show that the government could be compelled to acknowledge responsibility for losses tied to the World War II incarceration. Indeed, the Evacuation Claims Act illuminated both the possibilities and limitations of pursuing official compensation for the wartime incarceration. The postwar political landscape made it possible for Japanese Americans to extract concessions from the federal government, eager to distance itself from the World War II incarceration (along with other anti-Asian laws and policies), which remained a liability in the context of the Cold War. Yet doing so required that Japanese Americans play the role of model citizens and loyal patriots who deserved to be compensated for their losses. This dilemma would continue to shape Japanese American redress politics in the decades to come, even as the movement itself grew more diverse and the voices leading the charge more militant.

Laying the Groundwork: Campaigns of the 1960s and 1970s

During the late 1960s and 1970s, the push for monetary compensation and a formal apology from the government gained steam among various Japanese American groups and organizations. This renewed activism around redress came at a time when Japanese American politics were splintering and becoming more diverse. The hyperpatriotism espoused by Masaoka and the JACL fell out of favor as new generations of activists, inspired by the anti-racist and anti-imperialist movements of the time, brought new issues and perspectives to the table. In particular, opposition to the Vietnam War galvanized younger Japanese Americans, many of them Sansei (third generation), who began to connect the military actions in Southeast Asia with the longer history of anti-Asian racism and exclusion. They joined African American, Native American, and Chicano students and activists in demanding “third world liberation,” an end to US imperialism abroad and racism and economic exploitation at home.12 Some Nisei (second-generation Japanese Americans) survivors of the wartime incarceration also began to explicitly reject the conservative politics of the JACL and develop a more confrontational stance toward the government. For them, the Evacuation Claims Act and other such actions did not go far enough to address the fundamental injustice of the incarceration and would remain empty gestures as long as the government refused to acknowledge any responsibility or wrongdoing.

The growing calls for government accountability during this period reflected a shift in how Japanese Americans interpreted and remembered their wartime incarceration. In the immediate postwar period, the JACL crafted a version of history that emphasized Japanese American compliance and shied away from condemning the government for its actions. Some JACL leaders even echoed government justifications and lauded the leaders of the WRA for doing the best they could in a difficult situation. As the political landscape changed during the 1960s and 1970s, other Japanese Americans pushed back against this dominant narrative and reassessed the history of the incarceration. Scholarly works unearthed the history of resistance within the camps and refuted the government’s justification of military necessity. Museum exhibits educated public audiences about the dehumanization of camp life, while pilgrimages to former camp sites and other commemorative ceremonies brought Japanese Americans together to remember what happened and reflect on the lasting trauma of incarceration.13 As Japanese Americans came to view the incarceration as connected to a history of anti-Japanese racism, their calls for justice also intensified.

The Movement for Japanese American RedressClick to view larger

Figure 1. A family participates in the first Manzanar Pilgrimage, December 1969. Courtesy of Manzanar National Historic Site and the Evan Johnson Collection. This work is licensed under a Creative Commons Attribution–NonCommercial–Sharealike International.

Still, the JACL version of history remained the dominant one, and the JACL political agenda continued to hold considerable sway at the national level. JACL leaders remained staunchly opposed to any political action that could damage the organization’s relationship with the government. In 1969, Bill Hosokawa, a Nisei journalist who wrote a weekly column in the JACL newspaper, published the first popular account of Japanese American history called Nisei: The Quiet Americans. The book encapsulated JACL views about the place of Japanese Americans in US society. As the title suggests, Hosokawa presented the Japanese American story as one of quiet perseverance. In his telling, Japanese Americans experienced great hardship during World War II, yet never grew bitter or disillusioned, choosing instead to prove their loyalty through military service and patriotic expression.14 Though well received by critics and the mainstream public, The Quiet Americans was heavily criticized by Japanese American scholars and activists, who claimed that the book reinforced stereotypes of Japanese Americans as submissive model minorities and that it was out of step with the more radical political currents of the time.15

These internal debates and differing perspectives collided and, at times, came together in a series of battles that would lay the groundwork for redress. One of the most consequential was the campaign to repeal the Emergency Detention Act, Title II of the Internal Security Act of 1950 (hereafter Title II). Passed in 1950 during the height of the Cold War, Title II authorized the government to detain any person suspected of engaging in espionage, sabotage, or other actions that threatened US security in the time of war or invasion. The architects of Title II used the Japanese American incarceration as a foundation for the law, citing the 1944 Supreme Court decisions that had upheld the government’s justification of military necessity for detaining US citizens. The government also designated Tule Lake, a former Japanese American incarceration camp, as one of the six official detention sites under Title II. Though by the 1960s the law was effectively dead, as anti-communist hysteria subsided and the government cut all funding for the program, fears about the potential revival of Title II among leftist and radical groups sparked calls for its official repeal. Despite the law’s connection to the World War II incarceration, mainstream Japanese American leaders did not immediately take a public stance on the issue. Many were reluctant to champion a cause associated with the radical left and remained skeptical that a repeal was possible. It wasn’t until a handful of Nisei and Sansei activists initiated their own grassroots movement to support the repeal effort that JACL leaders reconsidered their stance and agreed to join the campaign, which was ultimately successful. On September 25, 1971, President Nixon signed a bill officially repealing Title II.16

The repeal movement succeeded largely because of Japanese American involvement. Japanese Americans organized letter-writing campaigns, public talks, and radio addresses to inform local communities about the issue and pressure politicians to support the repeal. The JACL used its political power to lobby sympathetic lawmakers, including Senators Daniel Inouye and Spark Matsunaga, to introduce a repeal bill. But more than their practical efforts, it was the connection between the World War II incarceration and the detention program authorized by Title II that made the difference. Japanese Americans who testified in congressional hearings invoked their own experiences during the war when arguing for the repeal of Title II. Though the testimonies varied in tone and message, taken together they presented a compelling picture of loyal citizens and patriotic Americans who been unfairly victimized by a program very similar to Title II. Their message appeared to resonate. Congress passed a repeal bill, with a handful of individual congressmen even expressing public remorse about the government’s actions during World War II.17

The fight to repeal Title II set the stage for a series of actions that would propel the Japanese American community toward redress. Practically, the repeal effort showed what could happen when different Japanese American factions came together around a single cause, with the mainstream JACL using its political connections and national reputation to win over skeptical lawmakers and the more radical groups working at a grassroots level to galvanize everyday Japanese Americans and other sympathetic parties. Symbolically, the Title II repeal movement also revealed the power of Japanese American victimhood. The connection Japanese Americans made between Title II and the World War II incarceration moved lawmakers precisely because of their status as innocent victims of government overreach. The story of their patriotism, loyalty, and postwar socioeconomic rise became inextricably linked with the government’s own understanding of the World War II incarceration and its willingness to address the past.

This dynamic persisted as Japanese Americans continued to mobilize during the 1970s, which included the successful campaigns to pardon Iva Toguri, a Nisei convicted of treason by the US government in 1949, and to officially rescind Executive Order 9066, which had authorized the mass removal and exclusion from the West Coast in 1942.18 In his 1976 proclamation rescinding Executive Order 9066, President Gerald Ford called the incarceration “a mistake,” celebrated the accomplishments of the Nisei veterans, and declared that “Japanese Americans were and are loyal Americans.”19 It was the closest Japanese Americans had come to an official apology and yet, like so many other government actions during this period, it came with conditions. What about those who weren’t loyal, who weren’t patriotic, and who didn’t conform to the role of model citizen? Were they also deserving of sympathy and contrition? Though the campaigns of the 1960s and 1970s proved that redress was well within reach, these victories also raised unsettling questions about the limits of pursuing this form of justice.

The Commission on Wartime Relocation and Internment of Civilians

In 1980, Congress formed the Commission on Wartime Relocation and Internment of Civilians (CWRIC) to “review the facts and circumstances” around Executive Order 9066, assess the impact of incarceration on Japanese Americans, and recommend suitable remedies.20 The formation of the CWRIC marked a new phase of the redress movement. No longer solely a grassroots effort among Japanese American organizations and activists, the government now had control over the outcome of redress and the conditions under which it would be decided. Japanese Americans thus faced a difficult decision: to continue to fight for redress on the government’s terms or on their own. In the end, Japanese Americans did both. While many Japanese Americans recognized the value of the CWRIC and joined together from across the political spectrum to support its work, they also pursued their own avenues for justice and accountability.

The idea of a congressional commission emerged as a compromise between JACL leaders and Japanese American politicians during a period in which redress activism was intensifying. In 1970, Nisei activist Edison Uno introduced a resolution during the JACL national convention that called for federal legislation to provide individual payments and an official apology to Japanese Americans for the wartime incarceration. Uno’s resolution went nowhere until the late 1970s when a new generation of leadership took over the JACL and began to pursue the redress question in earnest. The JACL formed a National Committee on Redress and conducted community surveys to gauge where Japanese Americans stood on the question. With the involvement of a mainstream organization such as the JACL, redress suddenly went from a fringe issue to a political possibility. This concerned Japanese American politicians who viewed redress legislation as unrealistic and worried about the political fallout. They urged the JACL to drop its calls for redress and instead support a congressional commission that would conduct an official review of the government’s actions during World War II. JACL leader John Tateishi assented, reasoning that a fact-finding mission would help educate the public about what happened and make it harder for the government to dismiss Japanese American claims. With JACL backing, Senators Daniel Inouye and Spark Matsunaga introduced a bill that would create the CWRIC, which passed easily in both chambers of Congress and was signed into law by President Jimmy Carter in 1980.21

The JACL’s decision to champion the congressional commission over redress legislation fractured what was then a fragile alliance between various factions of the Japanese American community. Though Japanese Americans had come together over the repeal of Title II and other political battles during the 1970s, old divisions still lingered. Some questioned the JACL’s true intentions when it came to redress, claiming that a commission was just a stalling tactic that would lead to nowhere. To others, that the JACL once again sided with politicians showed the organization’s true colors as the mouthpiece of the Japanese American elites.22 In response to JACL inaction on the issue, two groups, the National Council of Japanese American Redress (NCJAR) and the National Coalition for Redress and Reparations (NCRR), splintered off and formed their own independent campaigns.

NCJAR consisted of dissident JACL members in Seattle and Chicago who wanted more direct action on redress. In 1979, they moved ahead with their own redress bill that called for $15,000 in monetary payments plus $15 for each day of imprisonment. When the bill failed to gain traction in Congress, NCJAR members took the unprecedented step of filing a class action lawsuit against the US government for violations of legal and constitutional rights. The lawsuit demanded $27 billion in restitution, which amounted to approximately $220,000 for every individual incarcerated during the war.23 Though NCJAR lost its case, which was dismissed by a federal appeals court in 1987, the threat of the lawsuit and its high settlement demands helped sway government support for redress by allowing “advocates of the congressional route . . . to claim the more moderate middle ground.”24

NCRR was the second group to break away from the JACL-dominated redress coalition following its move to support the CWRIC over redress legislation. Made up of Sansei activists with roots in the Los Angeles area as well as progressive Japanese American organizations and college students, NCRR members viewed redress as part of a larger program of social change and equality in the United States and abroad. They worked hard to build alliances with other marginalized communities and saw their fight for redress as deeply connected to the anti-racist, anti-imperialist struggles of the time. Unlike the JACL, which maintained strong ties with politicians through its lobbying arm, the NCRR believed in grassroots organizing and spent considerable time on the ground raising awareness about redress among less visible Japanese Americans, including the elderly and poor.25

Meanwhile, the CWRIC moved ahead. Formed in 1980, the CWRIC had three directives from Congress. The first two involved reviewing the facts and circumstances surrounding Executive Order 9066, its implementation by the US military, and impact on both citizen and alien populations. At the urging of lawmakers from Alaska, Congress included Native Alaskans and their removal and detention during the war as part of the commission’s official review. Additionally, Congress asked the CWRIC to recommend appropriate remedies based on its findings. Beyond these explicit parameters, the CWRIC also sought to assess the government’s justification of military necessity, which had withstood several legal challenges and remained the official reasoning for the mass removal and incarceration of Japanese Americans. Though cracks had been appearing for several years, particularly with President Ford’s rescission of Executive Order 9066, military necessity had never been formally overruled or delegitimized. The real work of the CWRIC, therefore, was to mount a case against military necessity and present new evidence that could help explain the government’s decision to incarcerate 120,000 US citizens and resident aliens without due process.

Japanese Americans inserted themselves into every step of this official review. While still pursuing their own campaigns and avenues for government accountability, many Japanese Americans felt a responsibility to influence the process as best they could. The CWRIC hired Nisei activist Aiko Herzig-Yoshinaga as lead researcher, responsible for reviewing thousands of declassified government documents and other archival materials.26 Herzig-Yoshinaga was an advocate of NCJAR and had lent her considerable research skills to help build the organization’s class-action lawsuit against the government. When the CWRIC put out the call for research assistance, Herzig-Yoshinaga jumped at the chance. “I know quite a bit about this now,” she recalled, “so I guess why not, I’d like to make some contribution.”27 With Herzig-Yoshinaga at the helm, the CWRIC collected evidence showing that the government was not motivated by military concerns during World War II and had even suppressed reports that Japanese Americans posed no threat to national security. These documents formed the basis of the CWRIC’s final report to Congress, Personal Justice Denied, issued in February 1983.

In addition to archival research, the CWRIC also conducted public hearings in ten cities across the United States to assess the impact of incarceration on Japanese Americans. Here as well Japanese Americans made their voices heard. NCRR members utilized their grassroots networks to convince Japanese Americans to show up and testify. Concerned that Nisei veterans and other influential Japanese Americans would dominate the hearings, the NCRR worked to ensure a more diverse range of perspectives. According to NCRR leader Lillian Nakano, the organization struggled at first to mobilize everyday Japanese Americans, particularly women and older Nisei. “We used to have to talk to them a lot to convince them that they should be out there,” Nakano remembers, “because they were the ones that suffered the most.”28 Their persistence paid off. Unlike the hearings around the repeal of Title II, in which a handful of Japanese American leaders provided one streamlined narrative, the CWRIC testimonies ranged widely and covered a variety of topics and issues. For many, it was the first time speaking publicly about their experiences during the war. Owing largely to the NCRR’s organizing efforts, many more people showed up to testify than expected, speaking before overflow crowds and forcing the CWRIC to add additional time. In total, the CWRIC heard testimony from over 750 people; most were Japanese American, but not all. While the hearings helped shape the commission’s recommendations to Congress, they also provided a critical space for collective healing and galvanized Japanese Americans into new forms of activism.

The Movement for Japanese American RedressClick to view larger

Figure 2. A scene from the Commission on Wartime Relocation and Internment of Civilians hearing in Seattle, 1981. Courtesy of the National Archives and Records Administration.

Based on nearly three years of research, the CWRIC issued its findings and recommendations to Congress in 1983. Its first report, Personal Justice Denied, presented an overview of each stage of the incarceration process and its impact on Japanese Americans. Though the CWRIC included a short section on Native Alaskan removal and detention, the report focused mainly on the case of Japanese Americans. Personal Justice Denied refuted the justification of military necessity and provided clear evidence that the incarceration of Japanese Americans was instead fueled by “race prejudice, war hysteria, and a failure of political leadership.”29 Four months later, the CWRIC presented its recommendations, which included a formal apology, individual payments of $20,000 to survivors, and the creation of a foundation that would fund research and public education on the wartime incarceration of Japanese Americans.30 The work of the CWRIC greatly influenced Congress, which would go on to adopt nearly all of its recommendations in the final redress bill.

Many Japanese Americans welcomed the findings of the CWRIC and celebrated its outcome. The report validated what Japanese Americans had long known to be true: that the incarceration was not driven by military concerns but rather by anti-Japanese racism, and that this had caused irreparable harm to Japanese Americans and their families. But as much as Personal Justice Denied and the work of the CWRIC provided closure for some, it also left other issues unresolved. Though NCRR and other organizations worked to ensure diverse representation among the witnesses, the CWRIC did not treat all voices equitably.31 The CWRIC prioritized the testimonies that aligned with government views of redress, while marginalizing those who expressed criticism of the commission and the hearings process.32 The CWRIC report also glossed over Japanese Latin American detention and incarceration, despite the testimony of several survivors who spoke of being kidnapped from their home countries and sent to camps in the United States, then abandoned as stateless people after the war.33 Finally, by framing its work so narrowly around the issue of military necessity, the CWRIC did not address the deeper implications of mass incarceration during a time of war or national crisis. If the commission had found proof of military necessity, would the incarceration of Japanese Americans have then been justified? The overwhelming evidence of government misconduct allowed the CWRIC to sidestep the fundamental questions about race, war, and national security that the World War II incarceration had raised.

Civil Liberties Act of 1988 and Other Redress Actions

Though the CWRIC presented compelling evidence that the government had violated the rights of Japanese Americans and advised monetary compensation for their losses, both material and immaterial, Congress did not immediately act. In fact, Japanese Americans faced considerable obstacles in securing redress legislation. The makeup of the government had changed considerably from the late 1970s to 1983, with conservative Republicans taking control of Congress and Ronald Reagan being elected President in 1980. In addition to his broader commitment to cutting taxes and decreasing government spending, President Reagan remained personally opposed to redress, as did many members of Congress. Within this political climate, the Japanese American military veterans and other conservative voices played a key role in swaying congressional opinion. The Nisei veterans embarked on a massive lobbying campaign to convince skeptical lawmakers to support redress legislation. A growing cohort of Japanese Americans in Congress, who no longer viewed redress as a political liability, aided them in this effort. Stories of Nisei heroism and valor were also reportedly effective in gaining the support of President Reagan, who changed his mind on redress when he was reminded of his role in a 1945 ceremony that awarded posthumous honors to a Japanese American World War II soldier killed in combat.34 Their political networking paid off. During the fall and spring of 1987 and 1988, a redress bill passed both chambers of Congress, and on August 10, 1988 President Reagan signed the Civil Liberties Act into law.

Largely mirroring the recommendations of the CWRIC, the Civil Liberties Act stood as an important legislative achievement, but fell far short during the appropriations process. The Act approved $20,000 individual payments to survivors and established a $50 million public education fund (later reduced to $5 million owing to federal budget restrictions). It also acknowledged the injustice of the incarceration and offered a public apology to those affected by the government’s actions. However, when it came time to deciding who would receive monetary payments, some were not compensated equally while others were omitted entirely. Despite the hopes of many in the Japanese American community, Congress limited the redress payments to living survivors, leaving nothing for families of the deceased. Native Alaskans were granted monetary payments, but received only $5,000. Japanese Latin Americans were left out of the appropriations entirely. After several decades of legal battles, including a 1996 class action lawsuit against the federal government, Japanese Latin American survivors have yet to receive the full compensation given to other Japanese Americans.35 The distribution of funds began in 1991 under President George H. W. Bush, who accompanied the $20,000 checks with a signed letter of apology. Approximately 82,000 people received redress payments under the Civil Liberties Act, totaling over $1.5 billion.

The push for national redress legislation occurred alongside other movements for justice and accountability, including those on the local level. In California, Sansei activists pursued monetary compensation for Japanese American state employees who had been terminated from their jobs following the bombing of Pearl Harbor. Through independent research, they found that a high-ranking state official had orchestrated the dismissal of over 300 Japanese Americans owing to blatant anti-Japanese racism. With the help of a sympathetic lawmaker and the support of NCRR and local JACL chapters, they successfully pushed through a redress bill in 1982 that offered $5,000 in compensation for lost wages and unfair termination. Following the success of the California case, Japanese Americans began uncovering similar stories in jurisdictions large and small throughout the West Coast and mounted successful campaigns for restitution from the State of Washington, Los Angeles County, and the City of Seattle.36

Others sought redress through the judicial system. In the mid-1980s, Gordon Hirabayashi, Fred Korematsu, and Minoru Yasui decided to reopen their wartime convictions that had each resulted in cases heard by the Supreme Court. In 1942, all three men were arrested and imprisoned for violating government orders: Hirabayashi and Yasui refused to comply with the mandatory curfew, while Korematsu did not report to Tanforan Assembly Center. Their appeals reached the Supreme Court in 1944, which sided with the government in the cases of Hirabayshi vs. United States, Korematsu vs. United States, and Yasui vs. United States on the grounds of military necessity in the time of war. Though largely forgotten in the postwar years, these cases were revived during the redress era as symbols of Japanese American resistance. In her capacity as researcher for the CWRIC, Aiko Herzig-Yoshinaga, along with legal scholar Peter Irons, came across evidence that the government had deliberately suppressed reports from the Office of Naval Intelligence in 1942 stating that Japanese American posed little threat to national security. With clear evidence of government misconduct in hand, Hirabayshi, Korematsu, and Yasui mounted separate legal challenges to compel the courts to reopen their cases. To do so, they filed coram nobis petitions, a legal procedure used by felons to correct an error of fact based on new evidence not available at the time of trial. The basis of their coram nobis petitions was that the government withheld this exculpatory evidence from the Supreme Court in 1944 and presented false statements that shaped the outcome of the trials. After five years of preparations and legal proceedings, judges in all three cases accepted the petitions and formally vacated the wartime convictions.37

The Post-Redress Era

In 2018, the Supreme Court officially overturned its 1944 decision in the case of Korematsu vs. United States. Though in the 1980s the courts had vacated the wartime convictions of Fred Korematsu, Gordon Hirabayashi, and Minoru Yasui, the original Supreme Court rulings remained intact. This meant that the World War II incarceration still stood as legal precedent despite the government’s apology and acknowledgment of wrongdoing. That is, until 2018. In a strongly worded statement, the Supreme Court declared: “Korematsu was gravely wrong the day it was decided, has been overruled in the court of history, and – to be clear – ‘has no place in law under the constitution’” (the quoted passage taken from Justice Jackson’s dissent in the original Korematsu decision).38

Japanese American redress activists should have been elated. After all, Japanese American organizations had fought long and hard to overturn the Korematsu decision. The Supreme Court’s brief statement appeared to put an end to this decades-long legal battle. Or did it? The Supreme Court invoked Korematsu in the case of Trump v. Hawaii, in which it upheld the authority of the President to restrict the entry of citizens from eight predominately (though not exclusively) Muslim countries, known commonly as the Muslim Ban. By overturning Korematsu, the majority sought to distinguish the World War II incarceration, which Chief Justice Roberts called “morally repugnant,” from President Trump’s executive action. In a dissenting opinion, however, Justice Sotomayor argued that the majority’s use of Korematsu only served to highlight the similarities between the two and the underlying logic used to justify them. “As here,” she argued, “the Government invoked an ill-defined national security threat to justify an exclusionary policy of sweeping proportion.” In Justice Sotomayor’s eyes, the very existence of the travel ban showed that Korematsu lived on, despite the efforts of the majority to close the book on this “shameful” episode.39

Japanese Americans from across the political spectrum immediately denounced the 2018 Supreme Court decision. Many agreed with Justice Sotomayor and used their own experiences to draw attention to the injustice of the travel ban. “As a Japanese American who grew up behind barbed wire of U.S. internment camps,” wrote activist and actor George Takei, “I sensed the cold dread that Muslims must have felt . . . being painted with a broad brush as potential terrorists . . . because we Japanese Americans were likewise characterized as spies and saboteurs more than 75 years ago.”40 Displays of solidarity like Takei’s became common after redress, which motivated Japanese Americans to speak publicly about their experiences for the first time. In the ensuing years, many felt compelled to continue sharing these stories to educate the public and ensure that the World War II incarceration would not be repeated. If redress failed to dislodge the conditions that made the World War II incarceration possible, it also generated new forms of activism and galvanized Japanese Americans to speak out against racism and injustice.

Discussion of the Literature

The Japanese American redress movement remains a nascent field. Redress shows up most often in scholarly literature as the final chapter in historical overviews of the World War II incarceration. In these cases, authors include redress as a conclusion to the incarceration story and incorporate little new evidence or archival research on the subject. Of the standalone studies on redress, the bulk was published in the 1990s and early 2000s following the passage of the Civil Liberties Act of 1988. Though varied in focus and approach, these works celebrated redress as a hard-fought victory and unquestioned achievement, reflecting the position of the authors as proponents of redress or those with close ties to the movement. With historical distance, however, scholars have grown more critical of redress and have begun to reassess its legacy in relation to race and civil rights more broadly in the United States. The scholarship on redress roughly falls into three categories: movement biographies, legal studies, and revisionist approaches.

Movement biographies began appearing in the 1990s and were some of the first to document the movement itself. These studies used untapped sources including interviews and community records to tell the story behind the movement and how Japanese Americans achieved the major legislative and judicial victories. Though these works did not shy away from describing the political and ideological divisions within the movement, the authors focused exclusively on Japanese Americans and made little effort to connect redress with other social movements or broader historical trends.41 Achieving the Impossible Dream by Harry Kitano, Mitchell Maki, and S. Megan Berthold, for example, vividly described the last-minute efforts of Japanese American lobbyists to convince individual congressmen to support the Civil Liberties Act, yet did not address the larger political context of the 1980s and other factors that would explain why redress efforts succeeded during this era.42 While this scholarship laid important groundwork, it left key questions unanswered.

Legal studies on Japanese American redress filled in some of the gaps. Written mostly by attorneys and legal scholars involved in the coram nobis cases, these studies flourished during and after the 1980s and addressed three thematic concerns: the legal history of the wartime incarceration, the various forms of judicial redress, and the legal ramifications of the Civil Liberties Act.43 This body of scholarship differed somewhat from the movement biographies. In these works, scholars did more to connect redress to other legal cases and efforts by other groups to secure redress. Several of the authors published extensively on the question of African American reparations and how the Civil Liberties Act related to global redress movements.44 Others discussed the legal context of Japanese American incarceration and its implications for civil liberties in the United States.45 Still, this scholarship shared with the movement biographies an understanding of redress as an unquestioned victory. While the authors drew broader conclusions about its legacy, they also viewed redress in unambiguous terms and celebrated those who fought for it.

Revisionist works are those that present a more critical or ambivalent view on redress. While still acknowledging the significance of redress, these more recent works turn a critical eye on the movement itself and situate redress within a broader historical context.46 Revisionist approaches vary widely. Some examine the more personal and introspective ways that Japanese Americans grappled with the past and sought justice outside formal redress campaigns.47 Others discuss the limitations of the movement and how activists strategically reinforced the image of Japanese American loyalty and patriotism in order to obtain recognition from the government.48 In Rightlessness: Testimony and Redress in U.S. Prison Camps, Naomi Paik argues that true justice and accountability are not possible through state-sponsored redress and that the Civil Liberties Act represented the government absolving itself of guilt and thus demonstrating the redemptive power of US democracy.49 By comparing Japanese American incarceration to the detention of enemy combatants at Guantanamo, Paik further underscores how redress failed to dislodge the very conditions that made the World War II incarceration possible. If the revisionist works have one common theme, it is that redress did not conclude the story of the World War II incarceration.50 By framing the Civil Liberties Act as a starting point, not the end, revisionist approaches open up promising avenues for future research on the topic of Japanese American redress.

Primary Sources

The primary sources related to Japanese American redress vary widely. A great deal of material can be found online, including oral histories and community newspapers that documented the redress struggle for Japanese American audiences. Archival collections also exist in government, university, and community-based repositories. A limitation of this primary source material, both print and digital, is that it tends to represent the leaders of the movement and other high-profile figures. The grassroots perspective is often more elusive. As a more recent historical event, however, the archives of the Japanese American redress movement are far from complete and will continue to expand in the years to come.

Digital Sources

The widest range of primary sources can be found online in two major digital archives. The first is the Densho Digital Repository. Densho boasts one of the largest online primary source collections of Japanese American history. It features high-quality, fully transcribed videotaped interviews and tens of thousands of documents. The database is searchable by keyword and all the files are downloadable. Densho’s material on the redress movement is particularly rich. It features oral history interviews with many different people involved with the redress movement, from key leaders to grassroots supporters. The repository also contains photographs from both institutional and personal sources, and the collections of two community newspapers, the Pacific Citizen and Gidra. The Pacific Citizen was official newspaper of the JACL, while Gidra represented the grassroots perspectives.

The second online database is the archives of the Rafu Shimpo, a Japanese/Japanese American community newspaper founded in the early 20th century. The database is available with an institutional subscription. Rafu Shimpo was based in the Los Angeles area, a hub of early redress activism, and published bilingual Japanese/English editions. Unlike Gidra and the Pacific Citizen, which were geared toward Japanese American audiences, Rafu Shimpo represented the immigrant generations and those who did not speak English as their dominant language. California State University, Long Beach has the print collection if needed for further research.

Archival Sources

National Archives and Records Administration, College Park, MD

The most important government source related to Japanese American redress is the papers of the Commission on Wartime Relocation and Internment of Civilians (CWRIC), held in the National Archives. The bulk of the collection contains information related to the hearings, including video recordings and full transcripts. The video recordings are particularly valuable, as no other repository has the full set of twenty hearings. Another notable collection held by the National Archives is the records of the Evacuation Claims Act of 1948.

UCLA Charles E. Young Research Library, Los Angeles, CA

UCLA library has the most extensive manuscript collections related to Japanese American redress. It holds the personal papers of many Japanese American leaders and influential figures in the movement, including Aiko Herzig-Yoshinaga, the researcher who worked on several redress campaigns and uncovered key evidence revealing government misconduct, and Edison Uno, the Nisei activist whose 1970 proposal to the JACL for monetary compensation formally kicked off the redress campaign. Another important collection is the records of the Korematsu vs. United States coram nobis litigation of the early 1980s. The records consist largely of files from Korematsu’s legal team.

Japanese American National Museum (JANM), Los Angeles, CA

JANM’s collections rival those of UCLA in the coverage of Japanese American redress topics, but the archive itself is difficult to access. Because of JANM’s status as a community-based institution, the hours of the archive fluctuate and often depend on the availability of staff. It is highly recommended to call in advance before scheduling a research trip. With this in mind, JANM remains a key destination for primary source material on the redress movement. Notably, JANM has the collection of the Japanese American Citizens League, Southwest District Office (Los Angeles Chapter), with the bulk covering the redress period. JAMN’s archive also contains the papers of William Marutani, a Japanese American judge and member of the CWRIC; William Hohri, chairperson of NCJAR, the organization that filed a class-action lawsuit against the U.S. government; and Congressman Norm Mineta, who played a key role in the passage of the Civil Liberties Act of 1988.

Further Reading

Commission on Wartime Relocation and Internment of Civilians. Personal Justice Denied. Revised edition. Seattle: University of Washington Press, 2000.Find this resource:

Daniels, Roger, Sandra C. Taylor, and Harry H. L. Kitano, eds. Japanese Americans: From Relocation to Redress. Salt Lake City: University of Utah Press, 1986.Find this resource:

Ishizuka, Karen. Lost and Found: Reclaiming the Japanese American Incarceration. Urbana: University of Illinois Press, 2006.Find this resource:

Kang, Jerry. “Denying Prejudice: Internment, Redress, and Denial.” UCLA Law Review 51 (2004): 933–1013.Find this resource:

Maeda, Daryl. Chains of Babylon: The Rise of Asian America. Minneapolis: University of Minnesota Press, 2009.Find this resource:

Murray, Alice Yang. Historical Memories of the Japanese American Internment and the Struggle for Redress. Palo Alto: Stanford University Press, 2007.Find this resource:

Nakanishi, Don. “Surviving Democracy’s ‘Mistake’: Japanese Americans and the Enduring Legacy of Executive Order 9066.” Amerasia Journal 19, no. 1 (1993): 7–35.Find this resource:

Nikkei for Civil Rights and Redress. NCRR: The Grassroots Struggle for Japanese American Redress and Reparations. Edited by Lane Ryo Hirabayashi. Los Angeles: Asian American Studies Free Press, 2018.Find this resource:

Paik, Naomi. Rightlessness: Testimony and Redress in U.S. Prison Camps since World War II. Durham: University of North Carolina Press, 2016.Find this resource:

Tachiki, Amy, ed. Roots: An Asian American Reader. Los Angeles: UCLA Asian American Studies Center, 1971.Find this resource:

Wu, Ellen. The Color of Success: Asian Americans and the Origins of the Model Minority. Princeton: Princeton University Press, 2014.Find this resource:

Yamamoto, Eric, Margaret Chon, Carol L. Izumi, Jerry Kang, and Frank H. Wu, eds. Race, Rights and Reparation: The Law and Japanese American Internment. 2nd Edition. New York: Aspen Publishers, 2013.Find this resource:

Notes:

(1.) Richard Drinnon, Keeper of Concentration Camps: Dillon S. Myer and American Racism (Berkeley: University of California Press, 1989); and Brian Hayashi, Democratizing the Enemy: The Japanese American Internment (Princeton, NJ: Princeton University Press, 2004), 107–147.

(2.) Charlotte Brooks, “In the Twilight Zone between Black and White: Japanese American Resettlement and Community in Chicago, 1942–1945,” Journal of American History 86, no. 4 (2000): 1655–1687; and Greg Robinson, After Camp: Portraits in Midcentury Japanese American Life and Politics (Berkeley: University of California Press, 2015), 15–68.

(3.) Lane Ryo Hirabayashi, Japanese American Resettlement through the Lens: Hikaru Iwasaki and the WRA’s Photographic Section, 1943–1945 (Boulder: University of Colorado Press, 2009).

(4.) Ansel Adams, Born Free and Equal: The Story of Loyal Japanese-Americans (New York: U.S. Camera, 1944).

(5.) Jasmine Alinder, Moving Images: Photography and the Japanese American Incarceration (Urbana: University of Illinois Press, 2009), 44–74.

(6.) Linda Gordon and Gary Okihiro, eds., Impounded: Dorothea Lange and the Censored Images of Japanese American Internment (New York: W. W. Norton, 2008).

(7.) Naoko Shibusawa, America’s Geisha Ally: Reimagining the Japanese Enemy (Cambridge, MA: Harvard University Press, 2010).

(9.) Many Asian American groups, Japanese Americans included, mobilized during the immediate postwar period to end formal anti-Asian exclusion, including prohibitions on immigration and citizenship. For Japanese Americans, legal victories came with the 1948 Supreme Court case of Oyama vs. California, which effectively marked the end of alien land laws, and the Immigration and Nationality Act of 1952, which gave Japanese immigrants the right to naturalize as U.S. citizens. See Cindy I-Fen Cheng, Citizens of Asian America: Democracy and Race during the Cold War (New York: New York University Press, 2013).

(11.) The Evacuation Claims Act required proof of ownership for any property lost, which deterred many from filing in the first place. Those who did had to wait months and even years while the government considered their cases. In addition, the government did not include lost wages and capped individual claims at $2,500. Frank Chuman, Bamboo People: The Law and Japanese Americans (Delmar, CA: Publishers, Inc., 1976).

(13.) Yang Murray, Historical Memories of the Japanese American Internment, 185–286.

(14.) Bill Hosokawa, Nisei, The Quiet Americans: The Story of a People (New York: William Morrow, 1969).

(16.) Masumi Izumi, “Prohibiting ‘American Concentration Camps’: Repeal of the Emergency Detention Act and the Public Historical Memory of the Japanese American Internment,” Pacific Historical Review 74, no.2 (2005): 165–194.

(17.) Izumi, “Prohibiting ‘American Concentration Camps,’” 180–188.

(18.) Mitchell T. Maki, Harry H. L. Kitano, and S. Megan Berthold, eds., Achieving the Impossible Dream: How Japanese Americans Obtained Redress (Urbana: University of Illinois Press, 1999), 70–71 & 77–78.

(19.) Gerald R. Ford, “Proclamation No. 4417 – An American Promise,” February 19, 1976, The American Presidency Project.

(21.) Yang Murray, Historical Memories, 289–298.

(22.) Yang Murray, Historical Memories, 298–300.

(23.) Maki, Kitano, and Berthold, Achieving the Impossible Dream, 121–128.

(24.) Maki, Kitano, and Berthold, Achieving the Impossible Dream, 128.

(26.) Thomas Fujita-Rony, “‘Destructive Force:’ Aiko Herzig-Yoshinaga’s Gendered Labor in the Japanese American Redress Movement,” Frontiers: A Journal of Women Studies 24, no. 1 (2003): 38–60.

(27.) Aiko Hertzig-Yoshinaga, interview by Larry Hashima and Glen Kitayama, Densho, September 11, 1997.

(28.) Lillian Nakano, interview by Megan Asaka, Densho, July 8, 2009.

(29.) Commission on Wartime Relocation and Internment of Civilians, Personal Justice Denied, 18.

(30.) According to historian Alice Murray, the $20,000 figure was adopted from a JACL proposal developed in 1978 that asked for $25,000 individual payments to survivors (or their heirs if deceased). In the hearings, JACL leaders consistently urged the CWRIC to recommend $25,000 in monetary compensation. See Murray, Historical Memories, 296–297.

(32.) Paik, Rightlessness: Testimony and Redress in U.S. Prison Camps since World War II, 38.

(33.) Paik, Rightlessness: Testimony and Redress in U.S. Prison Camps since World War II, 47–49.

(34.) Maki, Kitano, and Berthold, Achieving the Impossible Dream, 189–197.

(35.) For more on Japanese Latin American internment and redress struggle, see Cathleen K. Kozen, “Traces of the Transpacific U.S. Empire: A Japanese Latin American Critique,” Amerasia Journal 42, no. 3 (2016): 108–128; and Nikkei for Civil Rights & Redress, NCRR: The Grassroots Struggle for Japanese American Redress and Reparations (Los Angeles: UCLA Asian American Studies Center Press, 2018), 306–312.

(36.) Kozen, “Traces of the Transpacific U.S. Empire: A Japanese Latin American Critique,” 117–121; and Robert Sadamu Shimabukuro, Born in Seattle: The Campaign for Japanese American Redress (Seattle: University of Washington Press, 2001), 75–100.

(37.) Roger Daniels, Japanese American Cases: The Rule of Law in Time of War (Lawrence: University Press of Kansas, 2013), 166–180.

(38.) Trump, President of the United States, et al. v. Hawaii, 585 U.S. (2018).

(39.) Trump, President of the United States, et al. v. Hawaii, 585 U.S. (2018).

(40.) George Takei, “America Will Fix the Mistake of Trump’s Travel Ban,” July 2, 2018, CNN Opinion.

(41.) See, for example, William Minoru Hohri, Repairing America: An Account of the Movement for Japanese-American Redress (Pullman: Washington State University Press, 1988); Robert Sadamu Shimabukuro, Born in Seattle: The Campaign for Japanese American Redress (Seattle: University of Washington Press, 2001); Leslie T. Hatamiya, Righting a Wrong: Japanese Americans and the Passage of the Civil Liberties Act of 1988 (Palo Alto: Stanford University Press, 1993); and Louis Fiset, “Redress for Public Employees of Japanese Ancestry in Washington State After World War II,” Pacific Northwest Quarterly 88, no. 1 (1996): 21–32.

(42.) Harry Kitano, Mitchell Maki, and S. Megan Berthold, Achieving the Impossible Dream: How Japanese Americans Obtained Redress (Urbana: University of Illinois Press, 1999).

(43.) See, for example, Eric K. Yamamoto et al., Race, Rights and Reparation: Law and the Japanese American Internment (New York: Aspen Publishers, 2001); Peter Irons, Justice at War: The Japanese American Internment Cases (Berkeley: University of California Press, 1983); Peter Irons, Justice Delayed: The Record of the Japanese American Internment Cases (Middletown, CT: Wesleyan University Press, 1989); Charles McClain, ed., The Mass Internment of Japanese Americans and the Quest for Legal Redress (New York: Routledge, 1994); and Roger Daniels, The Japanese American Cases: The Rule of Law in Time of War (Lawrence: University Press of Kansas, 2013).

(44.) Eric Yamamoto, “Racial Reparations: Japanese American Redress and African American Claims,” Boston College Third World Law Journal 13, no. 1 (1998): 477–523; and Eric Yamamoto, “What’s Next? Japanese American Redress and African American Reparations,” in Redress for Historical Injustices in the United States: On Reparations for Slavery, Jim Crow, and Their Legacies, ed. Michael T. Martin and Marilyn Yaquinto (Durham, NC: Duke University Press, 2007).

(45.) Lorraine Bannai, Enduring Conviction: Fred Korematsu and His Quest for Justice (Seattle: University of Washington Press, 2015; and Eric Yamamoto, In the Shadow of Korematsu: Democratic Liberties and National Security (New York: Oxford University Press, 2018).

(46.) See, for example, Alice Yang Murray, Historical Memories of the Japanese American Internment and the Struggle for Redress (Palo Alto, CA: Stanford University Press, 2007).

(47.) Mira Shimabukuro, Relocating Authority: Japanese Americans Writing to Redress Mass Incarceration (Boulder: University Press of Colorado, 2015); and Karen Inouye, The Long Afterlife of Nikkei Wartime Incarceration (Palo Alto, CA: Stanford University Press, 2016).

(48.) Glen Mimura, Ghostlife of Third Cinema: Asian American Film and Video (Minneapolis: University of Minnesota Press, 2009), esp. 81–120.

(49.) A. Naomi Paik, Rightlessness: Testimony and Redress in U.S. Prison Camps since World War II (Durham: University of North Carolina Press, 2016). For the inherent limitations of seeking state-based redress, see also, Chris Iijima, “Reparations and the ‘Model Minority’ Ideology of Acquiescence: The Necessity to Refuse the Return to Original Humiliation,” Boston College Third World Law Journal 19, no. 11 (1998): 385–427; and Jerry Kang, “Denying Prejudice: Internment, Redress, and Denial,” UCLA Law Review 55 (2004): 933–1013.

(50.) Many of the redress activists, for example, have continued to fight for justice within and outside the Japanese American community. For works that discuss these post-redress struggles, see Nikkei for Civil Rights and Redress, The Grassroots Struggle; and Eric Yamamoto and Liann Ebesugawa, “Report on Redress: The Japanese American Internment,” The Handbook of Reparations, ed. Pablo De Greiff (Oxford: Oxford University Press, 2010).