Legislative Analysis
Phone: (517) 373-8080
FRED KOREMATSU DAY
http://www.house.mi.gov/hfa
Senate Bill 18 (H-1) as reported from House committee Analysis available at
Sponsor: Sen. Stephanie Chang http://www.legislature.mi.gov
House Committee: Judiciary
Senate Committee: Civil Rights, Judiciary, and Public Safety
Complete to 4-27-23
(Enacted as Public Act 32 of 2023)
SUMMARY:
Senate Bill 18 would amend 2003 PA 225 to designate January 30 of each year as Fred
Korematsu Day in recognition of Fred Korematsu’s contributions to civil rights. 1
Fred Korematsu was an American citizen of Japanese ancestry who in 1942 was arrested for
violating an order that essentially required all Americans of Japanese ancestry in Alaska,
California, western Washington and Oregon, and southern Arizona 2 to leave their homes,
businesses, jobs, and schools to report for relocation to a government incarceration camp.3
Those subject to the order were allowed to bring with them only what they could carry. 4
Korematsu defied the order and contested his arrest and conviction for doing so, arguing that
the order violated the Fifth Amendment constitutional provision that says a person cannot be
deprived of life, liberty, or property without due process of law. He pursued his case all the
way to the United States Supreme Court, which in December 1944, in a 6-to-3 decision, ruled
against him.
Over the following years, Korematsu continued to fight to clear his record and for civil rights
protections for all American citizens. In 1983, his conviction was formally vacated by a federal
district judge. To date, the Supreme Court has not overruled its 1944 decision in Korematsu v
United States, although it included remarks disparaging Korematsu in an opinion handed down
in 2018.
January 30 was Fred Korematsu’s birthday. He died in 2005 at the age of 86.
The bill would take effect 90 days after being enacted.
Proposed MCL 435.304
1
The act currently designates March 31 as Cesar E. Chavez Day, July 14 as President Gerald R. Ford Day, and July 30
as Henry Ford Day.
2
https://www.nps.gov/articles/images/Visio-yellow-latest-WRA.jpg
3
Some 120,000 people were held in the camps, two-thirds of whom were American citizens. The vast majority, if not
all, of those who were not citizens had immigrated to the United States more than two decades earlier (before the
Immigration Act of 1924 prevented immigration from Japan). However, federal law prohibited them, on the basis of
race, from becoming naturalized citizens.
4
https://www.nps.gov/articles/historyinternment.htm
See also https://www.smithsonianmag.com/smithsonian-institution/eighty-years-after-us-incarcerated-japanese-
americans-trauma-scars-remain-180979519/
House Fiscal Agency Page 1 of 2
BACKGROUND:
In 2010, California established January 30 as Fred Korematsu Day of Civil Liberties and the
Constitution. Five other states have since enacted legislation declaring January 30 to be Fred
Korematsu Day: Hawaii (2013), Virginia (2015), Florida (2015), Arizona (2022), and New
Jersey (2023). Several more have dedicated the day by proclamation. 5
FISCAL IMPACT:
The bill would have no fiscal impact on the state or local units of government.
Legislative Analyst: Rick Yuille
Fiscal Analyst: Michael Cnossen
■ This analysis was prepared by nonpartisan House Fiscal Agency staff for use by House members in their
deliberations and does not constitute an official statement of legislative intent.
5
https://korematsuinstitute.org/wp-content/uploads/2022/02/FKD-Brochure.pdf
House Fiscal Agency SB 18 (H-1) as reported from House committee Page 2 of 2


Statutes affected:
Substitute (H-1): 435.301, 435.303
Senate Introduced Bill: 435.301, 435.303
As Passed by the Senate: 435.301, 435.303
As Passed by the House: 435.301, 435.303
Senate Concurred Bill: 435.301, 435.303
Public Act: 435.301, 435.303
Senate Enrolled Bill: 435.301, 435.303