Lake having been converted to a segregated detention center for "disloyal" Japanese American inmates. In an effort to halt her case, the War Relocation Authority had offered to release her from camp if she agreed not to return to the West Coast, but Endo refused and so remained in confinement. Endo, Korematsu, and end of internment The unanimous opinion ruling in Endo's favor was written by Justice William O. Douglas, with Justices Frank Murphy and Owen Roberts concurring. It stopped short of addressing the question of the government's right to exclude citizens based on military necessity but instead focused on the actions of the WRA: "In reaching that conclusion [that Endo should be freed] we do not come to the underlying constitutional issues which have been argued.... [W]e conclude that, whatever power the War Relocation Authority may have to detain other classes of citizens, it has no authority to subject citizens who are concededly loyal to its leave procedure." Because of that avoidance, it is very difficult to reconcile Endo with Korematsu, which was decided the same day. As Justice Roberts pointed out in his Korematsu dissent, distinguishing the cases required a reliance on the legal fiction that Korematsu dealt with only the exclusion of Japanese Americans, not their detention, and that Fred Korematsu could have gone anywhere else in the United States, when in reality he would have been subject to the detainment found illegal in Endo. In short, Endo determined that a citizen could not be imprisoned if the government was unable to prove disloyalty, but Korematsu allowed the government a loophole to punish that citizen criminally for refusing to be illegally imprisoned. The Roosevelt administration, having been alerted to the Court's decision, issued Public Proclamation No. 21 the day before the Endo and Korematsu rulings were made public, on December 17, 1944. It rescinded the exclusion orders and declared that Japanese Americans could begin returning to the West Coast in January 1945. See also Hirabayashi v. United States Yasui v. United States List of United States Supreme Court cases, volume 323 References External links United States Constitution Article One case law United States Supreme Court cases Internment of Japanese Americans 1944 in United States case law Suspension Clause case law United States Supreme Court cases of the Stone Court