Hoyt v. Florida
Encyclopedia
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 discriminate and unfair circumstances during her trial.
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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(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 discriminate and unfair circumstances during her trial.
Background
FloridaFlorida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
state law allowed the accessibility of jury duty
Jury duty
Jury duty is service as a juror in a legal proceeding. When a person is called for jury duty in the United States, that service is usually not optional: one must attend or face strict penalties. Employers are not allowed to fire an employee simply for being called to jury duty...
was not mandatory for women, only those who volunteered for the civil duty. The arguments put forward by the plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
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
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, it was held that the Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
statute for jury selection was not discriminatory.
Reasoning of the Court
- 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."
- 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
- List of United States Supreme Court cases, volume 368
- Taylor v. LouisianaTaylor v. LouisianaTaylor v. Louisiana, 419 U.S. 522 , is a significant Supreme Court of the United States case, which held women could not be excluded from a venire, or jury pool, on the basis of having to register for jury duty, thus overturning Hoyt v. Florida, the 1961 case that had allowed such a...
,