and too close akin to the kind of government we are fighting.... We must realize, as Henry Emerson Fosdick so wisely said, 'Liberty is always dangerous, but it is the safest thing we have.' Members of some Christian religious groups, particularly those who had formerly sent missionaries to Japan, were among the most tireless opponents of the incarceration policy. Some Baptist and Methodist churches, among others, also organized relief efforts to the camps, supplying inmates with supplies and information. Statement of military necessity as a justification of incarceration Niihau Incident The Niihau Incident occurred in December 1941, just after the Imperial Japanese Navy's attack on Pearl Harbor. The Imperial Japanese Navy had designated the Hawaiian island of Niihau as an uninhabited island for damaged aircraft to land and await rescue. Three Japanese Americans on Niihau assisted a Japanese pilot, Shigenori Nishikaichi, who crashed there. Despite the incident, the Territorial Governor of Hawaii Joseph Poindexter rejected calls for the mass incarceration of the Japanese Americans living there. Cryptography In Magic: The Untold Story of U.S. Intelligence and the Evacuation of Japanese Residents From the West Coast During World War II, David Lowman, a former National Security Agency (NSA) operative, argues that Magic ("Magic" was the code-name for American code-breaking efforts) intercepts posed "frightening specter of massive espionage nets", thus justifying incarceration. Lowman contended that incarceration served to ensure the secrecy of U.S. code-breaking efforts, because effective prosecution of Japanese Americans might necessitate disclosure of secret information. If U.S. code-breaking technology was revealed in the context of trials of individual spies, the Japanese Imperial Navy would change its codes, thus undermining U.S. strategic wartime advantage. Some scholars have criticized or dismissed Lowman's reasoning that "disloyalty" among some individual Japanese Americans could legitimize "incarcerating 120,000 people, including infants, the elderly, and the mentally ill". Lowman's reading of the contents of the Magic cables has also been challenged, as some scholars contend that the cables demonstrate that Japanese Americans were not heeding the overtures of Imperial Japan to spy against the United States. According to one critic, Lowman's book has long since been "refuted and discredited". The controversial conclusions drawn by Lowman were defended by conservative commentator Michelle Malkin in her book In Defense of Internment: The Case for 'Racial Profiling' in World War II and the War on Terror (2004). Malkin's defense of Japanese incarceration was due in part to reaction to what