Franklin v. South Carolina, 218 U.S. 161 (1910) was the trial of Pink Franklin for the murder of South Carolina Constable Henry H. Valentine in 1907. Franklin was a sharecropper who wished to leave his employer although his employer had advanced Franklin wages under a contract known as "peonage laws". A warrant was obtained and when Valentine came to the house, a shootout occurred, killing Valentine and injuring Franklin, his wife Patsy, and another constable who was there. The defense included claims that Franklin acted in self-defense and that the peonage laws were unjust. In appeal, the defense claimed that the make-up of the jury, all white based on the requirement that the jury be based on those who were eligible to vote, was based on unconstitutional racism in election laws stemming