a trial whose result is reliable. Where a lawyer’s incompetence involves the failure to exercise a cause challenge, the proper inquiry is not whether the trial court would have sustained the challenge had it been made at trial. The Singer test is not concerned with actual prejudice to a defendant. Singer’s “any reasonable doubt” standard encourages some liberality in granting cause challenges at a time when the cost to the legal system is minimal. After trial, the Strickland requirement of actual prejudice imposes a more stringent test before a new trial can be ordered for the failure to object to a person’s service on a jury. It is whether the lawyer’s failure to raise a challenge resulted in a biased juror serving on the jury. See Goeders v. Hundley, 59 F.3d 73, 75 (8th Cir.1995) (<HOLDING>); Hughes v. United States, 258 F.3d 453, 458
holding that the failure to strike potentially biased juror was not iac where decision was based on trial strategy holding that where a claim of ineffective assistance of counsel is grounded in the claim that counsel failed to strike a biased juror a defendant must show that the juror was actually biased against him holding that a defendant must show actual prejudice to succeed on an ineffective assistance of counsel claim holding that the district court did not abuse its discretion when the trial judge questioned the juror extensively enough to satisfy itself that the juror was not biased emphasis added recognizing a constitutional claim for ineffective assistance of counsel