The Frank case was considered a miscarriage of justice because there was substantial evidence that Leo Frank did not murder Mary Phagan. Anti-Semitism contributed to the way the trial was conducted. Evidence surfaced later that several of the jurors uttered anti-Semitic remarks. Furthermore, the prosecution’s star witness, African American janitor Jim Conley, was a troubled individual with a criminal record. Frank was convicted largely on Conley’s testimony. Conley testified that Phagan had gone upstairs to Frank’s office. The janitor then testified he heard a loud scream and saw Frank trembling with a rope in his hand and Phagan’s dead body on the ground. Conley said he and Frank carried the girl’s body to the basement where they deposited it. Many believe that Conley may have acted alone in the death of Phagan. After the U.S. Supreme Court denied Frank’s relief, Conley’s own attorney, William M. Smith, announced that he thought Conley was the likely culprit.