Question: J.E.B. v. Alabama ex rel. T.B. extended precedent in which 1986 case regarding race-based peremptory challenges in criminal trials?

full_context: Document 1: Reed v. Reed: Reed v. Reed, 404 U.S. 71 (1971) , was an Equal Protection case in the United States in which the Supreme Court ruled that the administrators of estates cannot be named in a way that discriminates between sexes.
Document 2: Allen Derr: Allen Richard Derr (April 5, 1928 – June 10, 2013) was an American lawyer who won Reed v. Reed, a landmark United States Supreme Court decision issued in 1971 who strengthened anti-discrimination protections for women. The Supreme Court ruled unanimously for Derr's client, Sally Reed, who sued her estranged husband, Cecil, over who should administer the estate of their late son following his suicide. Derr argued before the Court that the 14th Amendment of the United States Constitution forbid discrimination on the basis of gender. On November 22, 1971, the U.S. Supreme Court ruled unanimously in favor Derr's client, Sally Reed, in a decision written by Chief Justice Warren Burger.
Document 3: Edmonson v. Leesville Concrete Co.: 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.
Document 4: Civil Rights Cases: The Civil Rights Cases, 109 US 3 (1883) were a group of five US Supreme Court constitutional law cases. Against the famous dissent of Justice Harlan, a majority held the Civil Rights Act of 1875 was unconstitutional, because Congress lacked authority to regulate private affairs under the Fourteenth Amendment, and that the Thirteenth Amendment "merely abolishes slavery". The Civil Rights Act of 1875 had banned race discrimination in access to services offered to the public. The decision was effectively reversed in the jurisprudence of the Supreme Court from 1937, and finally by legislation under the Civil Rights Act of 1964.
Document 5: Davis v. Ayala: 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.
Document 6: V.L. v. E.L.: V.L. v. E.L., 577 U.S. ___ (2016) , is a case decided by the Supreme Court of the United States concerning the adoption rights of same-sex couples. In 2007, a Georgia Superior Court granted adoption rights to V.L., the partner of E.L., the woman who gave birth to their three children. However, after moving back to Alabama, the couple split up. E.L. tried to block V.L. from seeing the children, but V.L. filed a lawsuit seeking visitation and other parental rights. On September 18, 2015, the Supreme Court of Alabama ruled that the state did not have to recognize the adoption judgment, saying that the Georgia court misapplied its own state law. The court voided the recognition of the adoption judgment in Alabama. V.L. petitioned the United States Supreme Court to stay the ruling during her appeal and allow her to see her children. On December 14, 2015, the Supreme Court stayed the ruling pending their action on a petition for a writ of certiorari filed by V.L. On March 7, 2016, the Supreme Court of the United States reversed the decision of the Alabama Supreme Court by per curiam summary disposition.
Document 7: Georgia v. McCollum: 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.
Document 8: Browder v. Gayle: Browder v. Gayle, 142 F. Supp. 707 (1956), was a case heard before a three-judge panel of the United States District Court for the Middle District of Alabama on Montgomery and Alabama state bus segregation laws. The panel consisted of Middle District of Alabama Judge Frank Minis Johnson, Northern District of Alabama Judge Seybourn Harris Lynne, and Fifth Circuit Court of Appeals Judge Richard Rives. On June 5, 1956, the District Court ruled 2-1, with Lynne dissenting, that bus segregation is unconstitutional under the Fourteenth Amendment protections for equal treatment.
Document 9: Hernandez v. New York: Hernandez v. New York, 500 U.S. 352 (1991), was a decision by the United States Supreme Court, which held that a prosecutor may dismiss jurors who are bilingual in Spanish and English from juries that will consider Spanish-language testimony.
Document 10: Zubulake v. UBS Warburg: Zubulake v. UBS Warburg is a case heard between 2003 and 2005 in the United States District Court for the Southern District of New York. Judge Shira Scheindlin, presiding over the case, issued a series of groundbreaking opinions in the field of electronic discovery. Plaintiff Laura Zubulake filed suit against her former employer UBS, alleging gender discrimination, failure to promote, and retaliation. Judge Shira Scheindlin's rulings comprise some of the most often cited in the area of electronic discovery, and were made prior to the 2006 amendments to the Federal Rules of Civil Procedure. The relevant opinions in the field are known as Zubulake I, Zubulake III, Zubulake IV, and Zubulake V. In 2012, the plaintiff published a book about her e-discovery experiences titled "Zubulake's e-Discovery: The Untold Story of my Quest for Justice."
Document 11: Batson v. Kentucky: 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.").
Document 12: State v. Limon: State v. Limon (280 Kan. 275, 122 P.3d 22) is a 2005 Kansas Supreme Court case in which a state law allowing for lesser punishment for statutory rape convictions if the partners were of different sexes than if they were of the same sex was found unconstitutional under both the federal and Kansas state constitutions. It was among the first cases to cite the United States Supreme Court decision "Lawrence v. Texas" as precedent, months after the Virginia Supreme Court did similarly in "Martin v. Ziherl".
Document 13: Wesberry v. Sanders: Wesberry v. Sanders, 376 U.S. 1 (1964) was a U.S. Supreme Court case involving U.S. Congressional districts in the state of Georgia. The Court issued its ruling on February 17, 1964. This decision requires each state to draw its U.S. Congressional districts so that they are approximately equal in population.
Document 14: 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.
Document 15: Goesaert v. Cleary: Goesaert v. Cleary, 335 U.S. 464 (1948), was a United States Supreme Court case in which the Court upheld a Michigan law, which prohibited women from being licensed as a bartender in all cities having a population of 50,000 or more unless their father or husband owned the establishment. Valentine Goesaert, the plaintiff in the case, challenged the law on the ground that it infringed on the Fourteenth Amendment's Equal Protection Clause. Speaking for the majority, Justice Felix Frankfurter affirmed the judgment of the Detroit district court and upheld the constitutionality of the state law. The state argued that since the profession of bartending could potentially lead to moral and social problems for women, it was within the state's power to bar them from working as bartenders. Only when the owner of the bar was a sufficiently close relative to the women bartender could it be guaranteed that such immorality would not be present.
ground_truth: Batson v. Kentucky