A Florida statute automatically exempted women from jury duty and did not place women on jury lists. Women could, however, volunteer and register for jury duty. After an all-male jury convicted Mrs. Hoyt for murdering her husband, she appealed the decision to the Florida Supreme Court. The Florida Court upheld the conviction.
Did the Florida statute violate the Equal Protection Clause of the Fourteenth Amendment?
In a unanimous decision, the Court held that the statute was based on a reasonable classification and was therefore constitutional. Noting that women were "still regarded as the center of home and family life," the Court found that the states could relieve them from the civic responsibility of jury duty unless they themselves determined that such service was consistent with their own "special responsibilities." The Court held that the case was distinct from other cases involving racial discrimination in jury selection, and that male- female disproportions on jury lists carried no constitutional significance.
None