Taylor v. Louisiana, 419 U.S. 522 (1975), is a landmark decision of the US Supreme Court which held that systematically excluding women from a venire, or jury pool, by requiring (only) them to actively register for jury duty violated the defendant's right to a representative venire.. The court overturned Hoyt v. Florida,. the 1961 case that had allowed such a practice.
Background 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.Taylor v. Louisiana, 419 U.S. at 524. Both parties agreed:
Issues 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:Taylor v. Louisiana, 419 U. S. at 525-26.
A secondary issue was whether Taylor had standing, as a man who would not be excluded from jury duty in Louisiana, to challenge the rule.Pursuant to , see Taylor v. Louisiana, 419 U.S. at 525-26, 528, FN 12.
Decision The Supreme Court "changed its mind and ruled the affirmative registration process was unconstitutional:"Dean John Champion, Richard D. Hartley, and Gary A. Rabe, "Criminal Courts," p. 219 (2nd ed., Upper Saddle River, NJ: Pearson 2008), citing and .
On the secondary issue of standing, it held:
Reasoning The Courts' reasoning was based heavily on the precedent from prior case law: "The Court's prior cases are instructive":Taylor v. Louisiana, 419 U.S. at 526.
Duncan v. LouisianaDuncan v. Louisiana, 391 U.S. 145, at 155-156, 88 S. Ct. 1444 at 1450-1451, 20 L. Ed. 2d 491, 1968 U.S. LEXIS 1631 (1968). appears to have been especially important to the court for use as a precedent. It was a significant United States Supreme Court decision, which incorporated the Sixth Amendment right to a jury trial and applied it to the states.
Ballard v. United States (1946), another precedent, concerned the exclusion of "an economic or racial group".Ballard v. United States, . Ultimately, the line of cases come from Glasser v. United States (1942),Glasser v. United States, . Smith v. Texas (1940),Smith v. Texas, . Pierre v. Louisiana (1939),Pierre v. Louisiana, . and Strauder v. State of West Virginia (1880),Strauder v. State of West Virginia, . all of which concerned the exclusion of blacks from juries as unconstitutional violations of the Equal Protection Clause.
See also Women in United States juries
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