In October 1919 bloody riots erupted near Elaine, Arkansas, after a white mob attacked a mass meeting of black farmers for trying to organize a union. As many as two-hundred blacks and twenty whites were killed.  The black defendants were tried by an all-white jury. Twelve were sentenced to death and sixty-seven to long prison terms. The NAACP appealed the convictions to the Supreme Court. In 1923 the Supreme Court overturned the convictions in Moore v. Dempsey, ruling that the defendants’ mob-dominated trials were a violation of the due process guaranteed by the Fourteenth Amendment. The landmark decision reversed the court’s previous ruling in the 1915 case of Leo Frank, who was convicted of murdering Mary Phagan, a 13-year-old employee of the Atlanta pencil factory that he managed. Later, Frank’s death sentence was commuted by Georgia’s governor, which led a mob of angry citizens to storm the prison where Frank was being held and lynch him. As a result of the Moore ruling, Frank’s grateful lawyer, Louis Marshall, joined the NAACP’s legal committee.