mitsugi nishikawa, born in california to japanese parents, went to japan to study, and he was conscripted into the japanese military in early 1941. after the end of the war, nishikawa was informed by us officials that he had lost his citizenship because he had served in a foreign army. his case was eventually reviewed by the supreme court, which decided that the burden of proof must be on the government to prove that nishikawa's japanese military service was undertaken voluntarily before he could be stripped of his citizenship.