Hoyt v. Florida

Instead of following the implications of the Court's ruling in Ballard, the nine justices who ruled against Hoyt fell back on sexual stereotypes in upholding the Florida jury statute:

Despite the enlightened emancipation of women from the restrictions and protections of bygone years . . . [a] woman is still regarded as the center of home and family life. We cannot say that it is constitutionally impermissible for a State . . . to conclude that a woman should be relieved from the civic duty of jury service unless she herself determines that such service is consistent with her own special responsibilities.

It would be another 14 years before the Supreme Court would effectively overrule its holding in Hoyt with Taylor v. Louisiana (1975), in which a male defendant successfully fought his rape conviction by arguing that the Sixth Amendment right to be tried by a jury of his peers was violated by a state "volunteers only" jury service law that resulted in an all-male jury. Although the Court distinguished Hoyt on grounds that it had been decided on the basis of the Fourteenth Amendment, the Taylor Court found that provisions that systematically produce all-male jury panels--provisions like the one at issue in Gwendolyn Hoyt's case--are unconstitutional. This ruling was later extended in Duren v. Missouri (1979), in which the Court outlawed a state statute which allowed women to be exempted from jury service and which had resulted in juries that were at least 85 percent male.