Question: J.E.B. v. Alabama ex rel. T.B. extended precedent in which 1986 case regarding race-based peremptory challenges in criminal trials?
Context: Edmonson v. Leesville Concrete Company, 500 U.S. 614 (1991) , was a United States Supreme Court case which held that peremptory challenges may not be used to exclude jurors on the basis of race in civil trials.  "Edmonson" extended the court's similar decision in "Batson v. Kentucky" (1986), a criminal case.  The Court applied the equal protection component of the Due Process Clause of the Fifth Amendment, as determined in "Bolling v. Sharpe" (1954), in finding that such race-based challenges violated the Constitution. Blake Percival is the former Director of Fieldwork Services, WPA for USIS.  Percival became a whistleblower after alleging he was terminated from USIS for not ordering his subordinates to submit cases to the U.S. Government for payment that had not been completed.  Percival worked for USIS from 2001 to June 2011, when, according to his suit, he was fired after refusing to order his employees to continue an elaborate fraud known as dumping.  In July 2011 Percival filed a "qui tam" whistleblower suit under seal in U.S. District Court in Montgomery, Alabama.  Percival’s allegations were investigated by the U.S. Department of Justice (DOJ) and in October 2013 the DOJ joined Percival’s suit and removed the seal.  The case, "United States of America ex rel.  Blake Percival v. U.S. Investigations Services", Civil Action No. 11-CV-527-WKW, was filed in U.S. District Court, Middle District of Alabama (Northern Division).  The DOJ filed their formal complaint on January 22, 2014.  This case is ongoing, and was moved to Washington, D.C. on April 25, 2014. Davis v. Ayala, 576 U.S. ___ (2015) was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial.  The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985.  At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service.  The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy".  Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings. Georgia v. McCollum, 505 U.S. 42 (1992) was a case in which the Supreme Court of the United States held that a criminal "defendant" cannot make peremptory challenges based solely on race.  The court had previously held in "Batson v. Kentucky" (1986) that prosecutors cannot make peremptory challenges based on race, but didn't address whether defendants could use them.  The court had already ruled in "Edmonson v. Leesville Concrete Company" (1991) that the "Batson" prohibition also applies to civil litigants because they are state actors during the jury selection process. Batson v. Kentucky, 476 U.S. 79 (1986) , was a case in which the United States Supreme Court ruled that a prosecutor's use of peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race.  The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment.  The case gave rise to the term "Batson challenge", an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case.  Subsequent jurisprudence has resulted in the extension of "Batson" to civil cases ("Edmonson v. Leesville Concrete Company") and cases where jurors are excluded on the basis of sex ("J.E.B. v. Alabama ex rel.  T.B."). J. E. B. v. Alabama ex rel.  T. B., 511 U.S. 127 (1994), was a case in which the Supreme Court of the United States held that making peremptory challenges based solely on a prospective juror's sex is unconstitutional.  "J.E.B." extended the court's existing precedent in "Batson v. Kentucky" (1986), which found race-based peremptory challenges in criminal trials unconstitutional, and "Edmonson v. Leesville Concrete Company" (1991), which extended that principle to civil trials.  As in "Batson", the court found that sex-based challenges violate the Equal Protection Clause. Ex rel.  is an abbreviation of the Latin phrase ""ex relatione" (meaning "[arising] out of the relation/narration [of the relator]" ).  The term is a legal phrase; the legal citation guide, the "Bluebook", describes "ex rel."  as a "procedural phrase" and requires using it to abbreviate "on the relation of", "for the use of", "on behalf of", and similar expressions. Hermesmann v. Seyer ("State ex rel.  Hermesmann v. Seyer 847 P.2d 1273 (Kan. 1993)") was a precedent-setting Kansas, United States case in which Colleen Hermesmann successfully argued that a woman is entitled to sue the father of her child for child support even if conception occurred as a result of a criminal act committed by the woman.  The case was brought in her name by the then Kansas Department of Social and Rehabilitation Services. A struck jury is a multi-step process of selecting a jury from a pool.  First potential jurors are eliminated for hardship.  Second jurors are eliminated for cause by conducting voir dire until there is a pool available that is exactly the size of the final jury (including required alternates) plus the number of peremptory challenges available to each side.  Then the two sides exercise their peremptory challenges on the remaining pool, usually alternating.  This procedure "has its roots in ancient common law heritage". Relator , female relatrix , (Latin for "narrator") is the legal term meaning a private person at whose relation or on whose behalf an application for a quo warranto or mandamus is filed.  The relator appears as one beneficially interested, but the action is maintained on his behalf.  The relator furnishes the knowledge or facts on which an information or a proceeding in quo warranto is based.  Such a proceeding is usually in the name of the state, ex rel.  ("ex relatione" = "[arising] out of the narration") of the relator, and so is called an "ex rel.  action".
Answer: Batson v. Kentucky