Facts
- Billy J. Taylor was indicted in Louisiana for aggravated kidnapping and was tried in St. Tammany Parish.
- Louisiana law provided that women would not be drawn for jury service unless they first filed a written declaration requesting eligibility.
- The parties stipulated that women were about 53% of eligible jurors, yet they comprised no more than 10% of the jury wheel; during one period, 12 of 1,800 persons drawn for venires were women.
- Taylor’s petit jury venire contained 175 persons and no women; Taylor was tried by an all-male jury.
- Before trial, Taylor moved to quash the venire as unconstitutional; the trial court denied the motion.
- Taylor was convicted and sentenced under the then-applicable capital sentencing scheme; the Louisiana Supreme Court affirmed.
Issues
- Whether a male defendant has standing to challenge the systematic exclusion of women from jury service.
- Whether requiring women to opt in to jury service, resulting in near-exclusion of women from venires, violates the Sixth Amendment fair-cross-section requirement as applied to the States through the Fourteenth Amendment.
Decision
- The Supreme Court reversed and remanded.
- Taylor had standing to challenge exclusion of women even though he was not a member of the excluded group.
- The Louisiana opt-in scheme produced systematic exclusion of a large, distinct segment of the community and violated the Sixth Amendment requirement that petit juries be drawn from venires representing a fair cross-section.
- The State’s asserted reasons for the scheme were insufficient; the fair-cross-section requirement could not be displaced by merely rational justifications.
- The Court declined to follow contrary implications of earlier precedent that had tolerated broad sex-based exclusions or automatic exemptions that made venires overwhelmingly male.
Legal Principles
- The Sixth Amendment, applied to the States through the Fourteenth Amendment, requires that the venire from which a petit jury is chosen be drawn from a representative cross-section of the community.
- A defendant may challenge exclusion of a distinct community group from jury service regardless of whether the defendant belongs to that group.
- Systematic exclusion of women from jury panels violates the fair-cross-section requirement.
- Administrative convenience or traditional sex-role assumptions do not justify a jury-selection system that substantially removes women from jury pools.
Conclusion
The Court held that Louisiana’s opt-in requirement for women unconstitutionally produced jury venires that were not drawn from a fair cross-section of the community, and it allowed a male defendant to raise the claim, reversing the conviction for proceedings consistent with the Sixth Amendment standard.