Today marks the 56th anniversary of the profoundly disappointing case of Hoyt v. Florida. Hoyt stood for the premise that a Florida law that created extra hurdles for women to be on juries did not violate the equal protection rights of a female defendant who was convicted by an all-male jury. While this case set a profoundly disappointing president for sex discrimination, Hoyt was eventually expressly overturned 14 years later with the case Taylor v. Louisiana.
The case behind Hoyt was interesting to say the least. On September 20th, 1957, Mrs. Gwendolyn Hoyt was indicted on charges of 2nd degree murder. Ms. Hoyt had killed her husband during a marital dispute. Mrs. Hoyt had three children with her Mr. Hoyt, had suffered years of physical abuse, and Mr. Hoyt had separated from her to live with his mistress. During a visit to the family home, Mrs. Hoyt offered to forgive her husband’s infidelity is he would return home for their children. Mr. Hoyt refused her forgiveness and expressed his desire to separate. After the rejection, Mrs. Hoyt struck Mr. Hoyt in the head with a baseball bat. When Mrs. Hoyt realized the severity of her husband’s head wound she called their family doctor who refused her pleas to help. When Mrs. Hoyt eventually called for an ambulance, it was too late, and Mr. Hoyt died on the way to the hospital.
At the time, in Florida, women were not included in jury pools unless they went to district court office and specifically request to be put on the list of potential jurors. At the time of Mrs. Hoyt’s trial, only 10 of 10,000 names on the jury pool list were women. Mrs. Hoyt plead not guilty by reason of temporary insanity. The all-male jury took 23 minutes to find her guilty and sentence her to 30 years in prison. Mrs. Hoyt appealed her case arguing her equal protection rights had been violated by the Florida law, thus denying her a fair trial. Her appeals were rejected by the Florida Court of appeals, and the Florida Supreme Court. Mrs. Hoyt then sought a writ of certiorari from the Supreme Court on the issue of equal protection and was granted cert in early 1961.
The Supreme Court heard arguments on October 19th, 1961. Mrs. Hoyt argued that her 14th amendment equal protection rights because no women convicted her. Mrs. Hoyt reasoned that because the Florida law drastically lowered the number of possible female jurors, she was denied an equal opportunity to present her case to women who would have been more sympathetic to her claim of temporary insanity.
The State argued that most women could not serve on juries because of family responsibilities. The state further argued that the administrative cost of including all women in jury pools would be to great, as too much time and resources would be used because of the number of women who would be seeking exemptions from jury service. Finally, the State argued that even if more women had been included in the jury pool, Mrs. Hoyt would still have been convicted.
The Supreme Court rendered its judgment on November 20th, 1961. In a Unanimous decision the Court, led by Justice John M. Harlan II agreed with the State of Florida. The Court held that the Florida law was not unconstitutionally discriminatory. The Court reasoned that Florida, and 17 other states which had similar laws were excluding women for a reasonable, nondiscriminatory reason. The Court further praised those states which did exclude women for protecting women from the filth, obscenity, and obnoxious atmosphere of the courtroom. The Court finally held that Mrs. Hoyts claim of sex discrimination was distinct from the precedent set for racial discrimination in jury selection. Thus the Court Affirmed her conviction.
With her conviction affirmed, Mrs. Hoyt served the rest of her sentence before returning to society. While the decision in Hoyt was disappointing for its clearly sexist and discriminatory holding, The Court eventually overturned the Hoyt in Taylor. With Experienced Legal Representation, you can ensure your equal protections rights are not violated by the State.
Written by Hunter J. White
 Hoyt v. Florida, 368 U.S. 57, 82 S. Ct. 159 (1961)
 Taylor v. Louisiana, 419 U.S. 522, 95 S. Ct. 692 (1975)