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Taylor v. Louisiana

Supreme Court of the United States · 1975 · Civil Procedure

Civil ProcedureConstitutional LawJury trialSixth AmendmentFourteenth Amendmentfair cross sectionjury venirepetit jury

Facts

At the time of trial, Louisiana law provided that a woman would not be selected for jury service unless she had previously filed a written declaration of her desire to serve. In the relevant judicial district, 53% of those eligible for jury service were women, but no more than 10% of the persons on the jury wheel in St. Tammany Parish were women, and during an 11-month period only 12 women were among 1,800 persons drawn to fill petit jury venires. The parties stipulated that this discrepancy resulted from the operation of the Louisiana constitutional and statutory provisions. In Taylor's case, the venire of 175 persons contained no women.

Issue

Whether Louisiana's jury-selection system, which effectively excluded women from jury venires unless they affirmatively volunteered, violated a criminal defendant's Sixth and Fourteenth Amendment right to an impartial jury drawn from a fair cross section of the community. Also, whether a male defendant had standing to raise that claim.

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 jury trial, as applied to the States through the Fourteenth Amendment. Jury wheels, pools, panels, or venires must not systematically exclude distinctive groups in the community and thereby fail to be reasonably representative thereof; defendants are not entitled to a jury of any particular composition, but they are entitled to a venire drawn from a fair cross section of the community.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a felony prosecution in Columbus, Ohio, the county jury system draws names only from residents who have returned a special postcard affirmatively requesting jury duty. Census data show that women make up about half of eligible jurors, but over the last year only 7% of persons summoned for petit-jury venires were women because women returned the postcard far less often. Daniel Mercer, a man, moves before trial to quash the venire.

How should the court rule on Daniel's Sixth Amendment objection?

Explanation. The governing rule is that a criminal defendant has a Sixth Amendment right to a petit-jury venire drawn from a fair cross section of the community, and distinctive groups may not be systematically excluded from jury wheels, pools, panels, or venires. The majority also held that the defendant need not belong to the excluded group to raise that claim. Because the system's operation systematically yields severe underrepresentation of women, Daniel may object even though he is male.