## Facts

- Gwendolyn Hoyt killed her husband with a baseball bat and was charged in Florida with second-degree murder under a statute covering imminently dangerous acts evincing a depraved mind without premeditation.
- Hoyt’s defense at trial was temporary insanity amid marital conflict and alleged infidelity.
- Florida’s jury law allowed women to serve only if they affirmatively registered their desire to be placed on jury lists; men were included without such registration.
- Because few women registered, jury pools were overwhelmingly male.
- Hoyt was tried and convicted by an all-male jury after brief deliberations.
- On appeal, Hoyt challenged only the sex composition of the jury as unconstitutional.

## Issues

1. Whether Florida’s jury-selection scheme, which effectively exempted women unless they volunteered by registering, violated the Fourteenth Amendment by producing an all-male jury.
2. Whether the statute was unconstitutional on its face or unconstitutional as applied to Hoyt’s trial.

## Decision

- The Supreme Court unanimously affirmed the conviction.
- The Court held the statute constitutional on its face and as applied.
- The Court reasoned that the Fourteenth Amendment requires an impartially selected jury drawn from eligible community members, free from arbitrary and systematic exclusions, but does not require a jury matched to a defendant’s circumstances.
- The Court treated the statute as a reasonable legislative classification permitting the State to relieve women from jury service unless they chose to serve.
- The Court found no substantial evidence that Florida officials arbitrarily undertook to exclude women; the underrepresentation was attributed to low voluntary registration by women.

## Legal Principles

- The Fourteenth Amendment guarantees selection procedures that are not marked by arbitrary and systematic exclusion from jury service among those eligible.
- A state may create sex-based jury-service rules if the classification is viewed as reasonable and not invidiously discriminatory, including a system that conditions women’s inclusion on affirmative volunteering.
- Disproportionate male–female representation on jury lists, without proof of state-driven arbitrary exclusion, was not treated as constitutionally equivalent to race-based exclusion in jury selection.

## Conclusion

The Court upheld Florida’s women-volunteer jury statute and ruled that Hoyt’s conviction by an all-male jury did not violate the Fourteenth Amendment because the system was deemed a reasonable classification and not an arbitrary, systematic exclusion by the State.


Hoyt v. Florida, 368 U.S. 57 (1961)