In 1986, the United States Supreme Court held in Batson v. Kentucky that the Equal Protection Clause bars a state from challenging jurors based solely on their race or on the assumption that African American jurors as a group would be unable to impartially consider the state's case. Earlier in 1986, the New Jersey Supreme Court in State v. Gilmore barred bias-based challenges, relying on New Jersey's constitutional protection of freedom from discrimination, the right to a jury trial and the right to an impartial jury drawn from a representative cross-section of the community.