 Specifically, he alleged that all blacks had been systematically excluded from both the grand jury considering the original indictment against him and the trial jury considering his case.He further argued that he had been substantively denied the right to counsel, as his lawyer had been too intimidated by the threats of mob violence to file motions for a change of venue, a continuance, or a new trial, all of which could be reasonably expected under the circumstances.Johnson was thus about to be deprived of his life without due process.