The use of peremptory challenges is controversial as some feel it has been used to undermine the balanced representation on a jury which would occur using random selection. While courts are not allowed to strike out entire groups of people from a particular jury, some would argue that peremptory challenges give individual parties this power (Yeazell 624). This reach of power has allowed, and still can allow, attorneys to simply strike out groups of people, even if just on a whim (e.g. all football fans may be struck from the jury). However, in the criminal case "Batson v. Kentucky", 476 U.S. 79 (1986), it was held that the prosecution's actions of striking groups of people based on race violated parties' right to equal protection. This holding was further applied to civil cases in 1991 ("Edmonson v. Leesville Concrete Co.", 500 U.S. 614 (1991)). Despite this, it still remains in use in several jurisdictions and in some cases leads to extensive and expensive jury research, aimed at producing a favorable jury.