In Powers v. Ohio, 499 U.S. 400 (1991) the Supreme Court determined that a criminal defendant has standing to raise the third-party equal protection claims of jurors excluded by the prosecution because of their race. (Id. at p. 415.) It concluded that the discriminatory use of peremptory challenges causes a criminal defendant cognizable injury, and the defendant has a concrete interest in challenging the practice because racial discrimination in jury selection casts doubt on the integrity of the judicial process and places the fairness of the criminal proceeding in doubt. (Id. at p. 411.) The court also found that there was a close relationship between the criminal defendant and the excluded juror and they had a "common interest in eliminating racial discrimination from the courtroom." (Id. at p. 413.) The court stated: "This congruence of interests makes it necessary and appropriate for the defendant to raise the rights of the juror." (Id. at p. 414.) In Green v. Travis (2d Cir. 2005) 414 F.3d 288, the Second Circuit interpreted Powers v. Ohio (1991) 499 U.S. 400 as "dramatically lessening the import of Batson's 'cognizable racial group' language ... by holding that a criminal defendant has third-party standing to raise the equal protection claims of venirepersons who have been peremptorily excluded from a ... jury on account of purposeful racial discrimination, even if the defendant and the peremptorily excluded venirepersons were not of the same race." (Green, supra, 414 F.3d at p. 297.) This, along with the holding of Powers that the racially discriminatory peremptory challenge of one prospective juror, standing alone, violates the equal protection clause, led the Second Circuit to reject the contention that a defendant does not have to show that all venirepersons who were peremptorily excused belonged to the same " 'cognizable racial group.' " (Green, supra, at p. 297.) It added: "Powers makes clear that the only continuing relevance of Batson's 'cognizable racial group' language is the requirement that a defendant alleging purposeful racial discrimination ... must demonstrate that a peremptorily excused venireperson was challenged by reason of being a member of some 'cognizable racial group.' ... One venireperson cannot be excluded from a jury on account of race. A fortiori, several venirepersons of different races cannot be excluded from a jury on account of race." (Id. at pp. 297-298.)