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

<P0-S0> 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. <P0-S1>  The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. <P0-S2>  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. <P0-S3>  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. <P0-S4>  T.B."). <SEP> <P1-S0> Blake Percival is the former Director of Fieldwork Services, WPA for USIS. <P1-S1>  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. <P1-S2>  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. <P1-S3>  In July 2011 Percival filed a "qui tam" whistleblower suit under seal in U.S. District Court in Montgomery, Alabama. <P1-S4>  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. <P1-S5>  The case, "United States of America ex rel. <P1-S6>  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). <P1-S7>  The DOJ filed their formal complaint on January 22, 2014. <P1-S8>  This case is ongoing, and was moved to Washington, D.C. on April 25, 2014. <SEP> <P2-S0> 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. <P2-S1>  "Edmonson" extended the court's similar decision in "Batson v. Kentucky" (1986), a criminal case. <P2-S2>  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. <SEP> <P3-S0> J. E. B. v. Alabama ex rel. <P3-S1>  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. <P3-S2>  "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. <P3-S3>  As in "Batson", the court found that sex-based challenges violate the Equal Protection Clause.