Hoyt v. Florida

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Hoyt v. Florida
Seal of the United States Supreme Court.svg
Argued October 19, 1961
Decided November 20, 1961
Full case name Gwendolyn Hoyt v. Florida
Citations 368 U.S. 57 (more)
82 S. Ct. 159; 7 L. Ed. 2d 118; 1961 U.S. LEXIS 136
Prior history Appeal from the Supreme Court of Florida
Holding
The Florida jury service is not unconstitutional in not selecting women unless they are to volunteer for it, and that a jury should not be selected based on individual cases, but broadly indiscriminately.
Court membership
Case opinions
Majority Harlan, joined by unanimous
Concurrence Warren
Concurrence Black
Concurrence Douglas
Overruled by
Taylor v. Louisiana

Hoyt v. Florida, 368 U.S. 57 (1961), was an appeal by Gwendolyn Hoyt, who had killed her husband and received a jail sentence for second degree murder. Hoyt claimed that her all-male jury led to discrimination and unfair circumstances during her trial. The decision was subsequently overruled by Taylor v. Louisiana.

Background[edit]

Florida state law allowed the accessibility of jury duty was not mandatory for women, only those who volunteered for the civil duty. The arguments put forward by the plaintiff suggested that there had been jury discrimination, and, moreover, that the Florida statute actively seeks to keep women from serving. This was argued in that women were excluded solely due to their sex. Men were automatically registered for duty, even if they had submitted an argument against serving. Women, however, had to actively register if they wished to serve.

In a unanimous decision by the U.S. Supreme Court, it was held that the Florida statute for jury selection was not discriminatory.

Reasoning of the Court[edit]

  • The holding was based on "reasonable classification," allowing responsibility to the state to choose whom to include and exclude. In the closing arguments, it was noted that at the time, 17 other states also exempted women from jury duty unless they so chose to register, and that in this case at least, the jury was not selected unconstitutionally. The "practice of excluding women from the jury pool ... it reasoned," was done to protect women "from the filth, obscenity, and obnoxious atmosphere ... of the courtroom."[1]
  • The right to an impartially selected jury assured by the Fourteenth Amendment does not entitle one accused of crime to a jury tailored to the circumstances of the particular case. It requires only that the jury be indiscriminately drawn from among those in the community eligible for jury service, untrammelled by any arbitrary and systematic exclusions.
  • The Florida statute is not unconstitutional on its face, since it is not constitutionally impermissible for a State to conclude that a woman should be relieved from jury service unless she herself determines that such service is consistent with her own special responsibilities. (The Court held that the statute was based on a reasonable classification and was therefore constitutional. Noting that women were "still regarded as the center of home and family life," the Court found that the states could relieve them from the civic responsibility of jury duty unless they themselves determined that such service was consistent with their own "special responsibilities." The Court held that the case was distinct from other cases involving racial discrimination in jury selection, and that male-female disproportions on jury lists carried no constitutional significance.)
  • It cannot be said that the statute is unconstitutional as applied in this case, since there is no substantial evidence in the record that Florida has arbitrarily undertaken to exclude women from jury service.

See also[edit]

Further reading[edit]

References[edit]

  1. ^ Dean John Champion, Richard D. Hartley, and Gary A. Rabe, "Criminal Courts," p. 219 (2nd ed., Upper Saddle River, NJ: Pearson 2008), ISBN 978-0-13-118979-9 citing Hoyt v. Florida, 367 U.S. 57 (1961).

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