free before he was sent to the McNeil Island Federal Penitentiary when he refused to comply with a draft order. Later developments This case has been largely overshadowed by Korematsu v. United States, decided the following term, in which the Court directly addressed the constitutionality of the removal of Japanese Americans from the West Coast. But, though the Korematsu case (challenging the exclusion portion of Executive Order 9066) overshadowed the Hirabayashi case (challenging only the curfew portion of the order), the Court's opinion in Korematsu cited its Hirabayashi ruling, upholding the restrictions placed on Japanese Americans. The Hirabayashi case is notable also in that the three dissenters in Korematsu, Justices Roberts, Jackson, and Murphy had either been persuaded by fellow justices to vote with the majority or, in the case of Murphy, to concur. An article by historian Sidney Fine published in Pacific Historical Review in May 1964, "Mr. Justice Murphy and the Hirabayashi Case", pp. 195–209, shows how that Justice's initial draft opinion was a vigorous dissent, but that he eventually yielded to the arguments of his fellow Justices and issued a concurrence – which, in Fine's view, "bore a striking resemblance to the dissenting opinion he had intended to issue." In the Korematsu decision, Murphy's dissent was vehement, calling the majority opinion "legalization of racism." In 1986 and 1987, Hirabayashi's convictions on both charges were overturned by the U.S. District Court in Seattle and the Federal Appeals Court, because evidence arose that the Solicitor General's office (led by Charles H. Fahy) had cited examples of Japanese American sabotage in its 1943–44 Supreme Court arguments, despite having researched and debunked all the rumored incidents. In 2011, the Acting Solicitor General officially confessed error in that regard. The United States Court of Appeals for the Ninth Circuit issued the final decision as Hirabayashi v. United States in 1987. In May 2012, President Obama posthumously awarded Gordon Hirabayashi the Presidential Medal of Freedom, America's highest civilian honor. Eleven lawyers who had represented Fred Korematsu, Gordon Hirabayashi, and Minoru Yasui in successful efforts in lower federal courts to nullify their convictions for violating military curfew and exclusion orders sent a letter, dated January 13, 2014, to Solicitor General Donald Verrilli Jr. In light of the appeal proceedings before the U.S. Supreme in Hedges v. Obama, the lawyers asked Verrili to request the Supreme Court to overrule its 1943 decisions in Korematsu, Hirabayashi