What is the test for a defense attorney to make a peremptory challenge?

" 'We review a trial court's determination regarding the sufficiency of [the defense attorney's] justifications for exercising peremptory challenges " 'with great restraint.' " [Citation.] We presume that [the defense attorney] uses peremptory challenges in a constitutional manner and give[s] great deference to the trial court's ability to distinguish bona fide reasons from sham excuses. [Citation.] So long as the trial court makes a sincere and reasoned effort to evaluate the nondiscriminatory justifications offered, its conclusions are entitled to deference on appeal. [Citation.]' [Citation.]" (People v. Winbush, supra, 2 Cal.5th at p. 434.)

As explained in issue IV, ante, defense counsel was unable to state reasons for several challenges or clarify reasons that the court found were inconsistent with its own notes. A court should be "suspicious when presented with reasons that are unsupported" by the record of voir dire. (People v. Silva, supra, 25 Cal.4th at p. 385.)

As the parties argued the issue, however, defense counsel ultimately explained why and how he used his peremptory challenges:

Defense counsel added:

Page 37