How have the courts treated peremptory challenges against Black prospective jurors?

The only basis stated by defense counsel in support of defendant's Wheeler motion was that the prosecutor had exercised seven of his first nine peremptory challenges to remove Black prospective jurors. Defense counsel made no attempt to specify the number of Blacks in the venire or the composition of the remaining jurors. Apart, however, from the question of whether defendant made a record as complete as feasible, we conclude that defendant failed to demonstrate a strong likelihood that the Black prospective jurors who are members of a cognizable group were challenged because of their group association rather than because of any specific bias. (People v. Turner, supra, 42 Cal.3d 711, 719, 230 Cal.Rptr. 656, 726 P.2d 102.)