How have courts interpreted peremptory challenges in the past?

Appellant relies on People v. Fuentes (1991) 54 Cal.3d 707, 286 Cal.Rptr. 792, 818 P.2d 75 and People v. Granillo (1987) 197 Cal.App.3d 110, 242 Cal.Rptr. 639 as authority for the proposition that once a prima facie case has been made the court cannot return to the screening process, i.e., find no prima facie showing, and the prosecutor must then justify all peremptory challenges made to a member of that group thereafter until the conclusion of voir dire.

His reliance on those cases is misplaced. Initially, we point out that neither Fuentes nor Granillo concluded that in every instance the prosecutor must justify each and every subsequent peremptory made as to members of the group in question until the conclusion of voir dire, once a finding of a prima facie showing has been made. Moreover, those cases are factually distinguishable. Finally, this conclusion is contrary to the principle that a Wheeler claim may be waived as to a particular juror by the failure to renew it as to that juror. (People v. Dunn (1995) 40 Cal.App.4th 1039, 1053, 47 Cal.Rptr.2d 638 (review den.).)