What is the scope of the Wheeler rule on peremptory challenges?

The scope of the Wheeler rule must also be measured against language in Wheeler commenting on the proper exercise of peremptory challenges. The opinion suggests that persons may be legitimately excused based on their "clothes or hair length." (Id., at p. 275, 148 Cal.Rptr. 890, 583 P.2d 748.) In addition, victims of crime or persons having relatives in law enforcement are properly challengeable. (Ibid.) Although an argument can be made that the inclusion of such groups could significantly contribute to "the interaction of the diverse beliefs and values the jurors bring from their group experiences" (id., at p. 276, 148 Cal.Rptr. 890, 583 P.2d 748; see also Peters v. Kiff, supra, 407 U.S. at pp. 503-504, 92 S.Ct. at pp. 2168-2169), the level of societal bias and tradition of discrimination is presumably insufficient to justify limitation on the freedom of the peremptory challenge.