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

The prosecutor exercised 11 peremptory challenges, all to female prospective jurors. The jury as sworn included six female and six male jurors. Defendant did not assert gender bias as a ground for his Wheeler motion. Instead, he argued that two challenges were motivated solely by racial bias and that eight challenges were motivated solely by bias against persons opposed to the death penalty. We have already discussed the first argument. The trial court correctly rejected the second argument because persons opposed to the death penalty do not make up a cognizable class for Wheeler purposes. (People v. Zimmerman (1984) 36 Cal.3d 154, 160-161, 202 Cal.Rptr. 826, 680 P.2d 776.)