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Law School Case Brief

Taylor v. Louisiana - 419 U.S. 522, 95 S. Ct. 692 (1975)

Rule:

The selection of a petit jury from a representative cross section of the community is an essential component of the Sixth Amendment right to a jury trial.

Facts:

Prior to trial on a kidnapping charge, defendant Billy J. Taylor, a male, sought to quash the petit jury venire from which his jury would be selected, contending that women had been systematically excluded from the venire, thus depriving him of his federal constitutional right to a fair trial by a properly selected jury. Of the persons eligible for jury service in the judicial district, 53 percent were female, but no more than 10 percent of the persons on the jury wheel were women, and none were selected for service on the defendant's venire. The discrepancy between females eligible for jury service and those actually included in the venire resulted from the operation of Louisiana constitutional and statutory provisions (later repealed), which excluded a woman from jury service selection unless she had previously filed a written declaration of her desire to be subject to jury service. The defendant's motion to quash the venire was denied, and upon review in the Supreme Court of Louisiana after the defendant's conviction, it was held that the Louisiana constitutional and statutory provisions were constitutional. Defendant appealed.

Issue:

Was the state jury-selection scheme of the State of Louisiana, which excluded women from jury service selection unless they previously filed a written declaration of their desire to be subjected to jury service, violative of the Constitution?

Answer:

Yes.

Conclusion:

The United States Supreme Court noted that the selection of a petit jury from a representative cross section of the community was an essential component of the Sixth Amendment right to a jury trial. As such, the Court held that the Sixth and Fourteenth Amendments were violated by the operation of the Louisiana constitutional and statutory provisions governing jury service by women. According to the Court, the exclusion of women from jury service unless they volunteered could not be sufficiently justified on the ground that jury service would interfere with the distinctive role of women in society. The Court averred that it can no longer be held that women as a class may be excluded from jury service or given automatic exemptions based solely on sex if the consequence was that criminal jury venires were almost all male, and contrary implications of prior cases, e.g., Hoyt v. Florida, 368 U.S. 57, cannot be followed.  The United States Supreme Court reversed Taylor's conviction and remanded for further proceedings.

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