The Holland case contrasted with the 1986 case of Batson v. Kentucky in which the Supreme Court ruled that the race-based peremptory challenge of a black juror violated the right of a black defendant to equal protection under the 14th amendment. In the Holland case, the Supreme Court held that the constitutional guarantee of an impartial jury is no guarantee of a statistically representative jury and that impartiality may well require that the jury not be representative of the community at large. The implication of the Supreme Court's sixth amendment reasoning in Holland is to limit the reach of Batson. Many race-based peremptory challenges may remain virtually unassailable, even when scrutinized under equal protection. Moreover, prosecutors may be able to assume carte blanche to use peremptory challenges in nonracial contexts to give effect to assumptions about other in-group biases such as gender, sex, religion, and national origin. 44 footnotes