In Hamdi v. Rumsfeld (542 U.S. 507 [2004]) the United States Supreme Court recognized the liberty interests of those held as "an immediate threat to the national security of the United States." (Id. at 530.) The United States Supreme Court also acknowledged that there is a tension "between the autonomy that the Government asserts is necessary in order to pursue effectively a particular goal and the process that a citizen contends he is due before he is deprived of a constitutional right." (Id. at 528-529.) The court found that "Hamdi's 'private interest' . . . is the most elemental of liberty interests--the interest in being free from physical detention by one's own government." (Hamdi at 529.) While the Government's interests were found to be "substantial," the Supreme Court found that " 'in our society liberty is the norm,' and detention without trial 'is the carefully limited exception.' " (Hamdi at 529.) Thus, "we have always been careful not to minimize the importance and fundamental nature of the individual's right to liberty." (Hamdi at 529-530 [citations and internal quotation marks omitted].) Addressing the second prong of the Mathews v. Eldridge test, the Hamdi court noted that "[p]rocedural due process rules are meant to protect persons not from the deprivation, but from the mistaken or unjustified deprivation of life, liberty, or property." (Hamdi at 530.) Thus, "as critical as the Government's interest may be in detaining those who actually pose an immediate threat to the national security of the United States during ongoing international conflict, history and common sense teach us that an unchecked system of detention carries the potential to become a means for oppression and abuse of others who do not present that sort of threat." (Hamdi at 530.) In addressing the third prong of the Mathews v. Eldridge test, the Supreme Court held that allowing an individual accused of being an enemy combatant the ability to challenge his status at a hearing would "meet the goal of ensuring that the errant tourist, embedded journalist, or local aid worker has a chance to prove military error while giving due regard to the Executive once it has put forth meaningful support for its conclusion that the detainee is in fact an enemy combatant." (Hamdi at 534, 124 S Ct 2633, 159 L Ed 2d 578.)