In some cases, parties have appealed a verdict or judgment and asked it be made invalid because one or more peremptory challenges excluded a recognizable group from the jury. Though the "Batson" decision addressed jury selection in criminal trials, in 1991 the Supreme Court later extended the same rule to civil trials in "Edmonson v. Leesville Concrete Company". In 1994, in "J.E.B. v. Alabama ex rel. T.B."., the Court held that peremptory challenges based on sex alone violated the standard established in "Batson" as well.