''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
Murder is the unlawful killing of another human without justification or valid excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person without justification or excuse, especially the ...
. Although she had suffered mental and physical abuse in her marriage and showed neurotic, if not psychotic, behavior, a six-man jury deliberated for just 25 minutes before finding her guilty.
They sentenced her to 30 years of hard labor. 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
''Taylor v. Louisiana'', 419 U.S. 522 (1975), was a List of landmark court decisions in the United States, landmark decision of the US Supreme Court which held that women could not be excluded from a ''venire'', or jury duty, jury pool, on the basi ...
'' in 1975.
Background
Florida
Florida is a state located in the Southeastern region of the United States. Florida is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Bahamas and Atlantic Ocean, and to ...
state law did not require women to
serve on juries, unless they volunteered to do so. Most women in the state of Florida did not register, so they were exempted from jury services. The arguments put forward by the
plaintiff
A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of t ...
suggested that there had been jury discrimination, and, moreover, that the Florida statute actively seeks to keep women from serving. This would be known as " the continuing validity".
The continuing validity was jury slang for supporting the right to keep males as the primary, and only source, of jurors on these trials. 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. These women were merely recognized for their job of being "the center of home and family" and not in the courtroom.
Decision
In a unanimous opinion written by
Justice
Justice, in its broadest sense, is the principle that people receive that which they deserve, with the interpretation of what then constitutes "deserving" being impacted upon by numerous fields, with many differing viewpoints and perspective ...
John Marshall Harlan II
John Marshall Harlan (May 20, 1899 – December 29, 1971) was an American lawyer and jurist who served as an associate justice of the U.S. Supreme Court from 1955 to 1971. Harlan is usually called John Marshall Harlan II to distinguish him ...
, the
Supreme Court of the United States held the
Florida
Florida is a state located in the Southeastern region of the United States. Florida is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Bahamas and Atlantic Ocean, and to ...
jury selection statute was not discriminatory. Harlan based his conclusion upon the theory of "reasonable classification," which permits states to choose whom to include and exclude in jury selections. In oral 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 at least, in this case, 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." Harlan held 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 for the jury to be indiscriminately drawn from among those in the community eligible for jury service, irrespective of any arbitrary and systematic exclusions. Furthermore, Harlan held the Florida statute was not unconstitutional on its face since it was 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. Harlan noted that the statute was based on a reasonable classification and so was constitutional. Because women were "still regarded as the center of home and family life,"
Harlan 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." He also held that the case was distinct from other cases involving
racial discrimination in jury selection
Racial discrimination in jury selection is specifically prohibited by law in many jurisdictions throughout the world. In the United States, it has been defined through a series of judicial decisions. However, juries composed solely of one racial ...
and that male-female disproportions on jury lists carried no constitutional significance.
In popular culture
The movie ''
On the Basis of Sex
''On the Basis of Sex'' is a 2018 American biographical legal drama film based on the life and early cases of Ruth Bader Ginsburg, who was the second woman to serve as an Associate Justice of the United States Supreme Court. Directed by Mimi Led ...
'' covers the ''Hoyt v. Florida'' case when Ruth Bader Ginsburg is teaching "Sex Discrimination and the Law". Ginsburg concludes her lesson by telling her students that this case showed "Discrimination on the basis of sex is legal."
See also
*
List of United States Supreme Court cases, volume 368
This is a list of all the Supreme Court of the United States, United States Supreme Court cases from volume 368 of the ''United States Reports'':
External links
{{SCOTUSCases, 368
1961 in United States case law
1962 in United States case ...
*
Women in United States juries
The representation of Women on United States juries has drastically increased during the last hundred years because of legislation and court rulings. Until the latter part of the twentieth century, women were routinely excluded from or opted out ...
Further reading
*
References
External links
* {{caselaw source
, case = ''Hoyt v. Florida'', {{ussc, 368, 57, 1961, el=no
, courtlistener =https://www.courtlistener.com/opinion/106302/hoyt-v-florida/
, findlaw = https://caselaw.findlaw.com/us-supreme-court/368/57.html
, googlescholar = https://scholar.google.com/scholar_case?case=2709517418034000081
, justia =https://supreme.justia.com/cases/federal/us/368/57/case.html
, loc =http://cdn.loc.gov/service/ll/usrep/usrep368/usrep368057/usrep368057.pdf
, oyez =https://www.oyez.org/cases/1961/31
United States Supreme Court cases
United States Supreme Court cases of the Warren Court
Overruled United States Supreme Court decisions
1961 in United States case law
Batson challenge case law
United States gender discrimination case law
History of women in Florida