The notion of "levels of judicial scrutiny", including strict scrutiny, was introduced in Footnote 4 of the U.S. Supreme Court decision in "United States v. Carolene Products Co." (1938), one of a series of decisions testing the constitutionality of New Deal legislation. The first and most notable case in which the Supreme Court applied the strict scrutiny standard and found the government's actions constitutional was "Korematsu v. United States" (1944), in which the Court upheld the forced relocation of Japanese Americans in internment camps during World War II. In another case, it has been held that restricting access to unapproved prescription drugs is a compelling government interest.