Why was Batman's spirit in JSA #85

http://www.comicvine.com/jsa-85-the-living-must-answer/4000-135754/

In the issue the JSA is fighting the Gentleman Ghost and Jakeem goes to the spirit world and while there he's attacked by a bunch of ghost..to help him the Thunderbolt summons a bunch of dead heroes to help...one is Batman...but this is during One Year Later so at the time Batman is still alive...was this the spirit of Earth 2 Batman?

nothing?

Yeah, since Infinite Crisis had just happened the implication is that it was Earth-2 Batman's spirit.

that's what I figured but not a single person questioned it all except for Jakeem and all he got was "It's complicated" from the Thunderbolt