In Carratelli v. State, 961 So. 2d 312 (Fla. 2007), the Court addressed the standard that courts should apply in deciding whether counsel's failure to preserve a challenge to a potential juror constitutes ineffective assistance of counsel. Id. at 315. The Court examined and compared the standards for demonstrating reversible error on appeal and demonstrating prejudice in the postconviction context. Id. at 317-20. The Court noted that while the standard for obtaining a reversal upon the erroneous denial of a cause challenge was relatively lenient (a defendant need only show that an objectionable juror sat on the jury), the standard for prejudice in postconviction claims was more restrictive. Id. at 320. The Court found that applying the standard used on direct appeal in the postconviction context disregarded the fundamental differences between review on appeal and review on postconviction. See id. at 324. Hence, the Court concluded that a postconviction claim must be evaluated under the more rigorous standard of Strickland. See Carratelli, 961 So. 2d at 324. In Carratelli v. State, 961 So. 2d 312, 324 (Fla. 2007), the Court held that "where a postconviction motion alleges that trial counsel was ineffective for failing to raise or preserve a cause challenge, the defendant must demonstrate that a juror was actually biased" to be entitled to relief. Without a showing of such actual bias of the juror, the defendant cannot establish the prejudice required by Strickland. The Court explained in Carratelli that "actual bias means bias-in-fact that would prevent service as an impartial juror. Under the actual bias standard, the defendant must demonstrate that the juror in question was not impartial--i.e., that the juror was biased against the defendant, and the evidence of bias must be plain on the face of the record." Id. In Owen v. State, 986 So. 2d 534 (Fla. 2008), the Court applied the Carratelli standard to a claim that trial counsel was ineffective for not exercising a cause or a peremptory challenge to strike a potential juror. The Court held that there was no evidence of bias in the record where a juror stated that she "probably" would vote for the death penalty in the circumstance of multiple victims but ultimately stated that mitigating evidence such as testimony about the defendant's mental health could influence her to recommend a life sentence. Id. at 550. The Court explained: A juror is competent if he or she "can lay aside any bias or prejudice and render his verdict solely upon the evidence presented and the instructions on the law given to him by the court." Lusk v. State, 446 So. 2d 1038 at 1041 (Fla. 1984). Therefore, actual bias means bias-in-fact that would prevent service as an impartial juror. Under the actual bias standard, the defendant must demonstrate that the juror in question was not impartial--i.e that the juror was biased against the defendant, and the evidence of bias must be plain on the face of the record. Id.