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The person was Tomoya Kawakita and it should be understood from this case that treason is a very difficult charge to prove. And even when proved, it is hardly every easy to sentence the person to death. In the case of Kawakita, the last person to be accused of treason, (with the exception of the latest case against Adam Gandhan), Kawakita was first sentenced to death. His sentence was later turned into life imprisonment by President Eisenhower. This life imprisonment was also pardoned and he was deported to Japan.
There are actually five different forms of treason as mentioned in the English Law. However the U.S. Constitution adopted only two of those forms and they have already been mentioned above. Treason will be levied if the person has waged war against America or if he aided enemies of the country.
The Supreme Court has decided some of these important treason cases. And these proceedings often resulted in deeper interpretations...
For example the Constitution clearly states that two witnesses will be required to charge someone of treason or the person should confess in an open court. In Cramer v. United States, the Supreme Court decided that "every act, movement, deed, and word of the defendant charged to constitute treason must be supported by the testimony of two witnesses." In Haupt v. United States, this requirement was deemed unnecessary when the Supreme Court ruled that two witnesses were not needed to prove intent but they were required only to prove that the act had occurred. What this meant was that while the two witnesses are needed, they are only needed to testify that they saw the act; they are not required to prove that it was treason.
Michigan law defined treason in the same way as the federal constitution does. Under this law, however, no one has so far been successfully accused of treason.
References
US Constitution, Section 3
Michigan Constitution
http://www.mackinac.org/article.aspx?ID=7163
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