In the 1961 case Hoyt v. Florida, Gwendolyn Hoyt was convicted of murdering her husband by an all-male jury in a Florida state court. She appealed to the U.S Supreme Court arguing that she had been discriminated against because women were not included on the jury list unless they volunteered for service, whereas men were automatically included. This, she argued, violated her rights under the Fourteenth Amendment's Equal Protection Clause as it resulted in juries being predominantly male and thus biased towards men. The Supreme Court disagreed with Hoyt’s argument and upheld her conviction by a vote of 7-2. The majority opinion held that this system did not discriminate against women but rather recognized their role at "the center of home and family life". Therefore, according to them, it was reasonable for states to conclude that women should be relieved from civic responsibilities such as serving on juries if they didn't volunteer themselves.

In the dissenting opinion for Hoyt v. Florida, Justice Hugo Black argued that Gwendolyn Hoyt was denied her constitutional right to a fair trial by an impartial jury due to Florida's discriminatory jury selection process. He contended that the state law exempted women from serving on juries unless they proactively registered their interest, which resulted in a predominantly male jury pool and thus violated the Equal Protection Clause of the Fourteenth Amendment. Justice Black believed this system inherently biased against female defendants like Hoyt because it did not represent a cross-section of community perspectives. Furthermore, he disagreed with the majority's view that women could be excluded based on their domestic responsibilities or supposed lack of understanding about certain matters before courts. Instead, he asserted all citizens should have equal opportunities and obligations in public service regardless of gender.