Whether the Eighth Circuit erred in deferring to lower court findings regarding trial counsel's failure to remove a potentially biased juror who served as foreperson and previously worked at the Prosecuting Attorney's Office

Mr. Duck alleged that his trial counsel was ineffective for failing to remove presumed impartial jurors that sat on the jury. Should they have been dismissed for cause? Did the Eighth Circuit err in deferring to the state and district court finding that Mr. Duck was not prejudiced by his trial counsel ’s failure to remove jurors for cause when a juror who states she would “lean towards ” the state when the state presents their evidence; and responded that her work at the Prosecuting Attorney ’s Office would make it difficult for her to sit on the case. She was the jury Fore-person. 1