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Hoyt v. Florida, 368 US 57 (1961)

No, but...

In Hoyt v. Florida, Gwendolyn Hoyt was convicted of second degree murder in the death of her husband. On appeal, Hoyt claimed that the all-male jury was not representative of the community, and that Florida's venire (jury pool) statute systematically discriminated against women.

At the time, eighteen states, including Florida, had statutes or constitutional provisions either excluding women from jury duty, or requiring them to actively register. Men were automatically registered. The rationale, at the time, was that women needed to be protected from the vulgarity and obscenity of a trial.

The Supreme Court, under Chief Justice Earl Warren, unanimously upheld Florida's rule, holding that an "impartially selected jury" did not create an entitlement to a hand-selected jury with a particular gender mix. Further, the practice was not unconstitutional because Florida court records indicated they had not arbitrarily excluded women.


Taylor v. Louisiana, 419 US 522 (1975)

A similar case arose fourteen years later under the Burger Court. In Taylor, the defendant had been convicted of aggravated kidnapping by an all-male jury. On appeal, Taylor claimed 53% of the sampling area was female, but due to Louisiana's discriminatory practices, none of the 175 people in the jury pool for his trial had been female. Taylor asserted a right to be judged by a jury representative of the community.

In a 7-1 vote, the Burger Court agreed that the exclusionary practice was unconstitutional, and formally incorporated the Sixth Amendment, via the Fourteenth Amendment Due Process Clause, and applied it to the states. (Justice Rehnquist dissented)


The decision in Taylor v. Louisiana, (1975) overturned the precedent set in Hoyt v. Florida,(1961).

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Q: Did the US Supreme Court agree with Gwendolyn Hoyt in the Hoyt v. Florida case?
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