Taylor v. Louisiana
| Taylor v. Louisiana | |
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| Argued October 16, 1974 Decided January 21, 1975 |
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| Full case name | Billy J. Taylor v. Louisiana |
| Citations | 419 U.S. 522 (more)
95 S.Ct. 692, 42 L.Ed.2d 690
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| Prior history | Appeal from the Louisiana Supreme Court |
| Holding | |
| A criminal defendant's 6th and 14th Amendment Rights are violated by the systematic exclusion of women from jury service. | |
| Court membership | |
| Case opinions | |
| Majority | White, Douglas, Brennan, Stewart, Marshall, Blackmun, Powell |
| Concurrence | Burger |
| Dissent | Rehnquist |
| Laws applied | |
| U.S. Const. amend. XIV | |
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This case overturned a previous ruling or rulings
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| Hoyt v. Florida (1961) | |
Taylor v. Louisiana, 419 U.S. 522 (1975), is a landmark Supreme Court of the United States case, which held women could not be excluded from a venire, or jury pool, on the basis of having to register for jury duty. The court overturned Hoyt v. Florida, the 1961 case that had allowed such a practice.
Billy J. Taylor was indicted and tried for "aggravated kidnapping" under Louisiana's then-mandatory capital sentencing system. While armed with a butcher knife, he approached an automobile occupied by Mrs. Louise Willie, her daughter, and grandson, forced her to go to an abandoned road near Mandeville, where he raped her before robbing them. Both parties agreed:
53% of the persons eligible for jury service in these parishes were female, and that no more than 10% of the persons on the jury wheel in St. Tammany Parish were women. During the period from December 8, 1971, to November 3, 1972, 12 females were among the 1,800 persons drawn to fill petit jury venires in St. Tammany Parish. It was also stipulated that the discrepancy between females eligible for jury service and those actually included in the venire was the result of the operation of La.Const., Art. VII, § 41, and La.Code Crim.Proc., Art. 402. In the present case, a venire totaling 175 persons was drawn for jury service beginning April 13, 1972. There were no females on the venire. [His attorney objected....] After being tried, convicted, and sentenced to death, appellant sought review in the Supreme Court of Louisiana, where he renewed his claim that the petit jury venire should have been quashed. The Supreme Court of Louisiana, recognizing that this claim drew into question the constitutionality of the provisions of the Louisiana Constitution and Code of Criminal Procedure dealing with the service of women on juries, squarely held, one justice dissenting, that these provisions were valid and not unconstitutional under federal law.
The issue before the court was not whether Taylor actually kidnapped anyone, but whether he had a fair trial because Louisiana law had a "conceded systematic impact" to eliminate female jurors from his jury:
The issue we have, therefore, is whether a jury selection system which operates to exclude from jury service an identifiable class of citizens constituting 53% of eligible jurors in the community comports with the Sixth and Fourteenth Amendments.
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