What is the test for making a peremptory challenge?

"Peremptory challenges are a long-standing feature of civil and criminal adjudication. But the exercise of even a single peremptory challenge solely on the basis of race or ethnicity offends the guarantee of equal protection of the laws under the Fourteenth Amendment to the federal Constitution. [Citations.] Such conduct also violates [the parties'] right to trial by a jury drawn from a representative cross-section of the community under article I, section 16 of the state Constitution. [Citation.]" (People v. Gutierrez (2017) 2 Cal.5th 1150, 1157 (Gutierrez).)