SELYA, Circuit Judge. In this appeal, petitioner-

appellant Michel St. Jean, a state prisoner, challenges the dismissal of his federal habeas petition, which asserted

violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. After careful consideration, we affirm the denial of habeas relief.

I

We briefly rehearse the relevant facts and travel of the case. "Because this appeal involves a challenge to evidentiary sufficiency, we rehearse the facts in the light most compatible with the jury's verdict, consistent with record support." Leftwich v. Maloney, 532 F.3d 20, 21 (1st Cir. 2008). In conducting this analysis, we are aware of the fact that — on habeas review — "a determination of a factual issue made by a State court" is

"presumed to be correct." 28 U.S.C. § 2254(e)(1). This presumption extends to factual findings made by state appellate courts in the course of direct review. See Teti v. Bender, 507

F.3d 50, 58 (1st Cir. 2007). In turn, we draw upon the facts

recited by the Massachusetts Supreme Judicial Court (SJC), supplemented by other facts in the record consistent with that recitation. See Companonio v. O'Brien, 672 F.3d 101, 104 (1st

Cir. 2012).

The saga begins on September 1, 2010. On that afternoon, the petitioner, Alexander Gallett, and Gallett's girlfriend, - 2 -

Yamiley Mathurin, were at Aline Valery's house in Hyde Park, Boston. Before leaving her residence, Valery overheard the three

hatching a plan to rob someone. That evening, around 8 P.M., the trio boarded a bus to a vacant house in the neighborhood. At approximately 11 P.M., Mathurin asked Marie Tunis — who lived next to the vacant houses — for permission to use her telephone. Once leave was granted, Mathurin proceeded to call a pizzeria and order pizzas, chicken wings, and soda. She requested that the food be

delivered to the back door of the address of the vacant house and provided the petitioner's cell phone number as the call-back number. She also asked if the delivery driver would have change for a one-hundred or fifty-dollar bill.

At 11:30 P.M., Gallett borrowed a passerby's cell phone and called the same pizzeria. The passerby testified at trial that Gallett made the call while in front of the vacant house.

Richel Nova (the victim) arrived shortly thereafter with

the delivery. Mathurin escorted him up the rear staircase of the vacant house. Five minutes later, the petitioner, Gallett, and Mathurin — who was holding a pizza box — left the house and got into the victim's vehicle. The petitioner proceeded to drive the vehicle away.

After witnessing the three drive away, Michael Tunis, along with his brother and friend, entered the vacant house. Tunis found blood and chicken wings on the floor near the entryway. In - 3 - a room off the kitchen, Tunis discovered the victim lying on his back unresponsive and with visible puncture wounds. Tunis proceeded to call the police, who arrived at the vacant house around 12 A.M. They found the victim's body on the floor with his pant pockets pulled inside out. They also found a pizza warmer

bag, a bloody chicken wings box, a knife handle, a bloody and slightly bent knife blade, and blood on the door frame leading into the kitchen.

Meanwhile, the petitioner, Gallett, and Mathurin drove the victim's vehicle to the rear of a church parking lot — where it was later found. The pizzeria sign that had previously been atop the vehicle was found discarded behind the church. A white pizza box with a label listing the vacant house as the delivery address and the petitioner's cell phone number as the call-back number was recovered either near or inside the vehicle. Empty bleach and rubbing alcohol bottles were also found in proximity to or inside the vehicle.

Having abandoned the victim's vehicle, the three returned to Valery's house. They smelled of bleach and appeared anxious. Gallett had blood on his shirt and on the bottom of his shoes, while the petitioner had a cut on his right hand and was using a bandana to try and stop the bleeding.

Within two days, the police arrested the petitioner, Gallett, and Mathurin. All of them were later indicted for first-

- 4 -

degree murder, armed robbery, and breaking and entering in the nighttime with intent to commit a felony. Mathurin pleaded guilty.

The petitioner and Gallett proceeded to trial before a jury. At

the trial, redacted inculpatory statements from both the petitioner and Gallett were introduced into evidence as audio- video recordings. An abundance of forensic evidence that implicated the two defendants was also introduced, including fingerprints and deoxyribonucleic acid (DNA) found at the vacant house, in the victim's car, on the victim, on the pizza box, on the defendants' clothing, and on money that Mathurin gave to police

following her arrest. Throughout, the petitioner argued that, although he admittedly broke into and entered the vacant house, he neither participated in the victim's murder or robbery nor did he share the intent to commit the crimes.

On September 23, 2014, a state-court jury returned a general verdict finding the petitioner and Gallett guilty of first- degree murder under the theories of felony-murder and extreme atrocity and cruelty, armed robbery, and breaking and entering with intent to commit a felony. The petitioner was sentenced to life in prison without parole for first-degree murder, a concurrent five-to-seven-year sentence for armed robbery, and a concurrent one-to-three-year sentence for breaking and entering with intent to commit a felony.

- 5 - On direct review, the SJC affirmed. See Commonwealth v. Gallett, 119 N.E.3d 646 (Mass. 2019). In its opinion, the SJC rejected a multitude of the petitioner's contentions, including a challenge to the sufficiency of the evidence, a challenge to the admission of statements from Gallett's redacted police interrogation, a challenge to the admission of his own redacted statements, a challenge to various jury instruction requests, a challenge to the judge's statements to the jury as prejudicial, and a challenge to the judge's decision to limit the cross- examination of a medical examiner. The court concluded by stating that its review of the entire record, pursuant to Mass. Gen. Laws ch. 278 § 33E, revealed no reason to disturb the verdict. See id. at 652, 669. Fifteen months later, the petitioner repaired to the federal district court in search of a writ of habeas corpus. He named as the respondent the superintendent of the North Central Correctional Institution in Gardner, Massachusetts (for ease in exposition, however, we shall treat the Commonwealth of Massachusetts as the real party in interest). The petitioner advanced seven claims of error, all of which were rejected by the district court. See St. Jean v. Marchilli, No. 1:20-11139, 2022 WL 4817108, at *4 (D. Mass. Oct. 3, 2022). This timely appeal followed. - 6 - II We review de novo a district court's denial of a habeas petition. See Porter v. Coyne-Fague, 35 F.4th 68, 74 (1st Cir. 2022). Pursuant to the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214 (codified as amended at 28 U.S.C. § 2254), we shall withhold a writ of habeas corpus unless the state court decision either: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. 28 U.S.C. § 2254(d). This first showing, described in section 2254(d)(1), is further divided into two distinct avenues for relief: the "contrary to" clause and the "unreasonable application" clause. The "contrary to" clause applies when "the state court arrives at a conclusion opposite to that reached by [the Supreme] Court on a question of law or if the state court decides a case differently than [the Supreme] Court has on a set of materially indistinguishable facts." Williams v. Taylor, 529 U.S. 362, 413 (2000). The "unreasonable application clause" applies when "the state court identifies the correct governing legal principle from [the Supreme] Court's decisions but unreasonably applies that - 7 - principle to the facts of the prisoner's case." Id. The phrase "clearly established Federal law, as determined by the Supreme Court of the United States," means "the holdings, as opposed to the dicta, of [the Supreme] Court's decisions as of the time of the relevant state-court decision." Id. at 412. Although state courts must "reasonably apply" existing Supreme Court precedent, they do not need to "extend that precedent." White v. Woodall, 572 U.S. 415, 426-27 (2014) (emphasis in original). Moreover, the phrase "unreasonable application" means that the state court's application of the Supreme Court's holdings "must be 'objectively unreasonable,' not merely wrong; even 'clear error' will not suffice." Id. at 419 (quoting Lockyer v. Andrade, 538 U.S. 63, 75-76 (2003)). The state court's application of the Supreme Court's holdings is unreasonable "if, and only if, it is so obvious that a clearly established rule applies to a given set of facts that there could be no 'fairminded disagreement' on the question." Id. at 427 (quoting Harrington v. Richter, 562 U.S. 86, 103 (2011)). Finally, "evaluating whether a rule application was unreasonable requires considering the rule's specificity," such that "[t]he more general the rule, the more leeway courts have in reaching outcomes in case-by-case determinations." Yarborough v. Alvarado, 541 U.S. 652, 664 (2004). The second showing, described in section 2254(d)(2), requires that the state court's decision be "based on an - 8 - unreasonable determination of the facts" on the record before that court. This showing cannot be made when "'[r]easonable minds reviewing the record might disagree' about the finding in question." Brumfield v. Cain, 576 U.S. 305, 314 (2015) (alteration in original) (quoting Wood v. Allen, 558 U.S. 290, 301 (2010)). Even if we determine that a state court's decision involves an unreasonable application of clearly established federal law, "habeas relief will not follow automatically." Foxworth v. St. Amand, 570 F.3d 414, 425 (1st Cir. 2009). Prejudice is essential: only if the error is shown to have prejudiced the petitioner and "had a 'substantial and injurious effect or influence in determining the jury's verdict'" will habeas relief be warranted. Delaney v. Bartee, 522 F.3d 100, 105 (1st Cir. 2008) (quoting Brecht v. Abrahamson, 507 U.S. 619, 631 (1993)). The short of it is that our review of a state court's decision on the merits is subject to a number of "peculiarly deferential standards." Porter, 35 F.4th at 74 (quoting Cronin v. Comm'r of Prob., 783 F.3d 47, 50 (1st Cir. 2015)). Yet, "[e]ven in the context of federal habeas, deference does not imply abandonment or abdication of judicial review." Id. at 75 (alteration in original) (quoting Brumfield, 576 U.S. at 314). With this framework in place, we turn to an examination of the petitioner's claims regarding the SJC's opinion. We first - 9 - examine his contention that the SJC failed to follow clearly established precedent when it rejected his argument that there was insufficient evidence that he acted as either a principal or joint venturer in the killing and denied his motion for a required finding of not guilty. Next, we address his contention that the SJC's holding — that the trial court did not violate his Confrontation Clause rights when it allowed the jurors to read his codefendant's redacted statements — was based on an unreasonable determination of the facts and/or a misapplication of federal precedent. Third, we address his contention that the SJC misapplied clearly established precedent in holding that the trial court's refusal to allow him to cross-examine the medical examiner about the location of the wounds on his hands was harmless error. We then proceed to his contention that the SJC departed from clearly established precedent and made its decision on the basis of an unreasonable determination of the facts when it found no error in the trial court's failure to provide various jury instructions. Finally, we consider his contention that the SJC's decision that the trial court committed no error when it told the jurors that they were part of "the government" was contrary to and an unreasonable application of clearly established precedent. A The petitioner's first contention is that the SJC unreasonably sustained his conviction because the evidence was - 10 - insufficient to support a jury finding beyond a reasonable doubt that he acted as either a principal or joint venturer in the killing of the victim. In his view, this insufficiency violated his constitutional due process right to be convicted only upon proof beyond a reasonable doubt of every element of a crime. See In re Winship, 397 U.S. 358, 364 (1970) ("[T]he Due Process Clause [of the Fourteenth Amendment] protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged."). Jackson v. Virginia, 443 U.S. 307 (1979), provides the clearly established federal law governing direct review of sufficiency claims. Jackson instructs a reviewing court to ask "the relevant question [of] whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." Id. at 319 (emphasis in original). In reviewing a habeas petition that raises a sufficiency claim under Jackson, we apply — in light of AEDPA's command that we may not overturn an underlying state court decision rejecting a sufficiency challenge unless the decision is "objectively unreasonable," Parker v. Matthews, 567 U.S. 37, 43 (2012) (quoting Cavazos v. Smith, 565 U.S. 1, 2 (2011)) — a "twice-deferential standard," id. Our inquiry focuses on "whether the state court['s] ruling that the evidence is constitutionally sufficient was itself - 11 - 'unreasonable.'" Winfield v. O'Brien, 775 F.3d 1, 8 (1st Cir. 2014) (quoting 28 U.S.C. § 2254(d)(1)). "'Unreasonable' in this context means that the decision 'evinces some increment of incorrectness beyond mere error.'" Id. (quoting Leftwich, 532 F.3d at 23). With these principles in mind, we consider the SJC's resolution of the petitioner's sufficiency challenge. Before the SJC, the petitioner contended that the evidence was insufficient to establish that he acted as either a principal or joint venturer in the killing. See Gallett, 119 N.E.3d at 658. The Commonwealth argued that there was sufficient evidence to support a conviction under a theory of felony-murder — with armed robbery as the predicate felony — and under a theory of extreme atrocity and cruelty. See id. Following established Massachusetts law, the SJC determined that it did not need to "examine the sufficiency of the evidence separately as to principal and joint venture liability," but could limit its inquiry to "whether the evidence is sufficient to permit a rational juror to conclude beyond a reasonable doubt that the defendant knowingly participated in the commission of the crime charged, with the intent required to commit the crime." Id. (quoting Commonwealth v. Zanetti, 910 N.E.2d 869, 884 (2009)). Building on this foundation, it observed that the Commonwealth only had to prove that the petitioner "was a joint venturer in an - 12 - armed robbery and that the victim's death occurred in the commission or attempted commission of that armed robbery." Id. To find the petitioner guilty under a theory of felony- murder with armed robbery serving as the underlying felony, the SJC explained, the Commonwealth had to prove that he "was part of a venture in which at least one of the coventurers was armed with a dangerous weapon, either applied violence to the victim's body or put the victim in fear, and took the victim's property with the intent to steal it." Id. Viewing the evidence in the light most favorable to the Commonwealth, the SJC determined that: Valery testified that she overheard the [petitioner, Gallett,] and Mathurin planning to rob someone. . . . The [petitioner, Gallett,] and Mathurin ordered pizza to be delivered to a vacant house. Mathurin asked if the delivery driver could change a one hundred or fifty dollar bill. [The petitioner] always carried a knife on his person, and Gallett carried his knife when he left the house. The jury reasonably could infer that [the petitioner] was armed with a knife; thus, the Commonwealth was not required to prove that [the petitioner] knew that Gallett was armed. The victim was lured into the vacant house and stabbed sixteen times. There was evidence of [the petitioner]'s bloody footprints inside the house, and [the petitioner] had the victim's blood on his jeans. Furthermore, Tunis testified that he saw Mathurin walk the victim to the rear door of the house and then witnessed the [petitioner, Gallett,] and Mathurin leave together. The jury could reasonably infer that [the petitioner] was inside the house. With [the petitioner] driving the victim's vehicle, the [petitioner, Gallett,] and - 13 - Mathurin then fled the scene. The [petitioner, Gallett,] and Mathurin abandoned the vehicle at the rear of a church parking lot. . . . Valery testified that the [petitioner, Gallett,] and Mathurin were nervous and smelled of bleach when she saw them later that night. Upon discovering the victim's body, police noticed that the victim's pockets were turned inside out. Reasonable inferences from the evidence showed that [the petitioner] was armed with a knife, either applied violence to the victim's body or put the victim in fear, and took the victim's property — the pizza, money, and vehicle — with the intent to steal it. Id. at 658-59. Given these facts, the SJC supportably concluded that "[t]he evidence was more than sufficient to permit a reasonable jury to find that the [petitioner] committed the murder under a theory of felony-murder." Id. at 658. There was more. To find the petitioner guilty under a theory of extreme atrocity or cruelty, the SJC explained that the Commonwealth had to prove that he "knowingly participated in the killing, that he intended to cause death or grievous bodily harm or engaged in an act a reasonable person would know created a plain and strong likelihood of death, and that the killing was committed with extreme atrocity or cruelty." Id. at 659. Assessing the evidence in the light most favorable to the Commonwealth, the SJC reasonably determined that: Fair inferences from the evidence showed that [the petitioner] was armed with a knife, planned to rob someone, lured the victim into the vacant house, and attacked the victim. The victim was stabbed sixteen - 14 - times. . . . [The petitioner] always carried a knife and had the victim's blood on his jeans and his sneakers. Furthermore, he had multiple cuts on his right hand. Although [the petitioner's] theory at trial was that he cut his hand by punching a window at the vacant house, [the petitioner] told doctors at a subsequent emergency room visit that he had cut his hand with a pocketknife; [and] told officers during his interrogation that he was cut with a knife during a fight. Id. at 659-60. The SJC concluded, "the evidence supports the conviction of murder under a theory of extreme atrocity or cruelty as well." Id. at 660. In this court, the petitioner contends that the SJC failed to follow clearly established precedent when it rejected his argument that the evidence was insufficient to support his conviction. He advances two reasons in support of this claim. First, he claims that, because the Commonwealth presented no evidence that he stabbed the victim, it was unreasonable for the SJC to find that the evidence was sufficient to support his conviction under either a theory of felony-murder or a theory of extreme atrocity or cruelty. Second, he claims that there was insufficient evidence to find that he was a joint venturer. This gap exists because the Commonwealth needed to establish either that he had knowledge that Gallett was armed or that he was himself armed with a knife. And yet, he claims, the evidence that the Commonwealth proffered to establish the latter fact — the testimony of Valery — was insufficient and circumstantial. After all, he - 15 - notes, Valery had only known him for a few weeks and "she had only seen [him] carry a pocketknife on a few occasions in the recent past." Inasmuch as her testimony "does not support an inference that he 'always' carried a knife," no reasonable jury could have determined that he was guilty under either theory — and the SJC was unreasonable in concluding otherwise. The district court rejected the claim that the SJC failed to follow clearly established precedent, and so do we. The SJC resolved the petitioner's sufficiency claim under the Massachusetts standard laid out in Commonwealth v. Gomes, 61 N.E.3d 441, 447 (2016). See Gallett, 119 N.E.3d at 658. Because this standard mirrors that of Jackson, we hold that the SJC's decision did not deviate from clearly established federal law. See Housen v. Gelb, 744 F.3d 221, 225 (1st Cir. 2014). Nor do we see any foundation for the petitioner's more specific claims as to why the SJC erred when it rejected his argument that the evidence was insufficient to support his conviction. The SJC appropriately noted that, because the petitioner was convicted on a joint-venture theory, it did not need to "examine the sufficiency of the evidence separately as to principal and joint venture liability." Gallett, 119 N.E.3d at 658 (quoting Zanetti, 910 N.E.2d at 884). Instead, it was only required to inquire into "whether the evidence is sufficient to permit a rational juror to conclude beyond a reasonable doubt that - 16 - the defendant knowingly participated in the commission of the crime charged, with the intent required to commit the crime." Id. (quoting Zanetti, 910 N.E.2d at 884). With respect to the conviction under a theory of felony- murder with armed robbery as the predicate offense, the SJC only needed to find that there was sufficient evidence to prove that the petitioner "was part of a venture in which at least one of the coventurers was armed with a dangerous weapon, either applied violence to the victim's body or put the victim in fear, and took the victim's property with the intent to steal it." Id. The evidence amply demonstrated that the petitioner, Gallett, and Mathurin planned the robbery, successfully lured the victim into a vacant house with the intent to commit the robbery and — during the course of the robbery — stabbed and killed him. Even though there was no direct evidence that the petitioner was the one who stabbed the victim, there was plenty of evidence to establish that he was a joint venturer. As such, the petitioner's first argument is beside the point. So, too, the evidence supported the finding that the petitioner was armed with a knife during the robbery. On this record, we have little difficulty concluding that the SJC was not "objectively unreasonable" in its determination. Parker, 567 U.S. at 43 (quoting Cavazos, 565 U.S. at 2). Valery's testimony underpinned this finding: in response to the question "How often - 17 - had you seen [the petitioner] with a knife?" she testified that "He always carried it on him." Even though the petitioner contends that testimony should be interpreted more narrowly, this argument does not move the needle. See Porter, 35 F.4th at 75 (explaining that "demanding showing" that "the state court decision 'was based on unreasonable determination of facts' . . . cannot be made when '[r]easonable minds reviewing the record might disagree' about the finding in question" (alteration in original) (quoting Brumfield, 576 U.S. at 314)). If more evidence is needed to support the finding that the petitioner was armed with a knife — though surely it is not — the SJC also pointed to the fact that the petitioner had the victim's blood on his jeans, see Gallett, 119 N.E.3d at 659, and that the petitioner had multiple cuts on his right hand, which he admitted were knife wounds when speaking with emergency room doctors, see id. at 660. With respect to the conviction under a theory of extreme atrocity or cruelty, the SJC needed to find that there was sufficient evidence to prove that the petitioner "knowingly participated in the killing, that he intended to cause death or grievous bodily harm or engaged in an act a reasonable person would know created a plain and strong likelihood of death, and that the killing was committed with extreme atrocity or cruelty." Id. at 659. In this instance, the SJC's finding of sufficient evidence was reasonable. As we already have determined, the evidence was - 18 - sufficient to show that the petitioner was armed with a knife. By the same token, it was reasonable to determine that the evidence showed that the petitioner — along with Gallett and Mathurin — attacked the victim and did so with extreme atrocity or cruelty. We therefore hold that the SJC's determination that there was sufficient evidence was not unreasonable. B We next consider the petitioner's claim that his Confrontation Clause rights were violated.

The Constitution guarantees that "[i]n all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him." U.S. Const. amend.

VI. In Bruton v. United States, 391 U.S. 123 (1968), the Supreme

Court held that a defendant is deprived of this right "where the powerfully incriminating extrajudicial statements of a

codefendant, who stands accused side-by-side with the defendant, are deliberately spread before the jury in a joint trial," and the codefendant "does not testify and cannot be tested by cross-

examination." Id. at 135-36. This violates the Constitution, the Court made clear, even if the jury receives limiting instructions to disregard such statements. See id. at 135 (explaining that

"the risk that the jury will not, or cannot, follow instructions is so great, and the consequences of failure so vital to the - 19 - defendant, that the practical and human limitations of the jury system cannot be ignored").

In Richardson v. Marsh, 481 U.S. 200 (1987), the Supreme

Court clarified Bruton. It held that Bruton does not apply "when the codefendant's confession is redacted to omit any reference to

the defendant, but the defendant is nonetheless linked to the confession by evidence properly admitted against him at trial."

Id. at 202. In Bruton, the Court explained, "the codefendant's confession 'expressly implicat[ed]' the defendant as his accomplice" and "at the time that confession was introduced there was not the slightest doubt that it would prove 'powerfully incriminating.'" Id. at 208 (alteration in original) (quoting

Bruton, 391 U.S. at 124 n.1, 135). By contrast, the confession in Richardson "was not incriminating on its face, and became so only

when linked with evidence introduced later at trial (the defendant's own testimony)." Id. Consistent with the foregoing, the Richardson Court held that "the Confrontation Clause is not violated by the admission of a nontestifying codefendant's

confession with a proper limiting instruction when . . . the confession is redacted to eliminate not only the defendant's name, but any reference to his or her existence." Id. at 211.

Richardson's bottom line was that, whereas statements that are incriminating "only when linked to other evidence" can be cured by proper limiting instructions, "facially incriminating" statements

- 20 - cannot. Id. at 209, 211; see United States v. Vega Molina, 407

F.3d 511, 520 (1st Cir. 2005) ("Statements that are incriminating only when linked to other evidence in the case do not trigger application of Bruton's preclusionary rule.").

Richardson was not the Supreme Court's last word on the scope of Bruton. In Gray v. Maryland, 523 U.S. 185 (1998), the Court recounted that "Richardson placed outside the scope of Bruton's rule those statements that incriminate inferentially."

Id. at 195. But — the Gray Court stressed — "inference pure and simple cannot make the critical difference." Id. Rather, the applicability of Richardson "must depend in significant part upon the kind of, not the simple fact of, inference." Id. at 196

(emphasis in original).

The codefendant's statement at issue in Gray was a response to the question, "Who was in the group that beat

Stacey[?]" Id. at 192. The redacted statement — as read to the jury — was "Me, deleted, deleted, and a few other guys." Id. at

196. When this statement appeared in the transcript, which was entered into evidence, it read "Me, , and a few other guys." Id. at 192. The Court recognized that "the jury [had to] use inference to connect . . . [this] redacted confession with the defendant."

Id. at 195. Even so — and despite the fact that it was not possible to infer solely from the text of the codefendant's redacted statement to whom the word "deleted" referred — the Court held

- 21 - that the redacted confession was facially incriminatory. See id.

"[W]e believe," Justice Breyer wrote, that "considered as a class, redactions that replace a proper name with an obvious blank, the word 'delete,' a symbol, or similarly notify the jury that a name has been deleted are similar enough to Bruton's unredacted confessions as to warrant the same legal results." Id.

To explain why Gray was distinguishable from Richardson, the Court focused on the different "kind of" inference at issue in each case. Id. at 196 (emphasis in original). In Richardson, the "inferences involved statements that did not refer directly to the defendant himself and which became incriminating 'only when linked with evidence introduced later at trial.'" Id. (quoting

Richardson, 481 U.S. at 208). Gray, however, was a horse of a

different hue: there, the inferences "involve statements that, despite redaction, obviously refer directly to someone, often obviously the defendant," and the jury could "ordinarily" draw

these inferences "immediately." Id. What is more, in Gray, "the redacted confession with the blank prominent on its face, in Richardson's words, 'facially incriminat[ed]' the codefendant."

Id. (emphasis in original) (quoting Richardson, 481 U.S. at 209).

As such, while Richardson lay outside the scope of Bruton, Gray fell within its ambit.

- 22 - In the last analysis, Gray makes clear that, even when the jury must engage in some inferential reasoning in order to conclude that a codefendant's statement is incriminating, the statement still may fall within the scope of Bruton. For the statement to do so, though, the inference that is necessary to make it incriminating must be one 'that a jury ordinarily could make immediately, even were the confession the very first item introduced at trial,' such that the statement 'obviously' and 'directly' implicates the defendant in the crime. United States v. de Leon-De La Rosa, 17 F.4th 175, 191 (1st Cir. 2021) (quoting Gray, 523 U.S. at 196).

Against this backdrop, we turn to the case at hand. At the trial, Gallett did not testify, but a redacted audio-video

recording of his statements was played for the jury. For ease in reference, the jury was given a redacted transcript of Gallett's statements. Prior to playing the recordings, the judge informed the jury that this transcript was redacted, that they were not to speculate about the gaps or the reasons for the gaps in the transcript, and that the transcript was not evidence.

Before the SJC, the petitioner argued that the use and admission of the redacted audio-video recording of Gallett's statements and the use of the redacted transcript of his statements violated Bruton. The gaps in the recording and the blank spaces

- 23 - in the transcript, he argued, directly inculpated him by inviting the jury to speculate on the identity of the redacted accomplice. The SJC rejected this argument, holding "that there was no Bruton violation because Gallett's redacted statements did not name expressly, implicate, or obviously refer to [the petitioner] so as to be 'facially' incriminating." Gallett, 119 N.E.3d at 660 (quoting Gray, 523 U.S. at 196). The SJC offered a plethora of reasons to substantiate this conclusion: that, given that there were three people involved in the killing of the victim (Gallett, the petitioner, and Mathurin), "[i]t would not have been obvious to the jury that the blank space was specifically referring to [the petitioner]," id. at 661; that, "even if we read in specific pronouns to the transcript, a single pronoun, if not referencing a specific individual, would not raise a Bruton issue in these circumstances," id.; that the petitioner's argument that the jury was able to combine the audio-video recording and the transcript "to form the opinion that the blank spaces in the transcript referred to [the petitioner]" was a weak one, given that "[e]ven where pronouns such as 'us' and 'we' were redacted, the blank spaces that remained were in the transcripts only," id.; that the judge's limiting instructions concerning the transcript "were sufficient to obviate [the petitioner's] concern over the gaps," id.; that the "redacted statements incriminate [the petitioner] only to the extent that the jury accepted the other evidence - 24 - against [the petitioner] that places him at the scene of the crime," id.; that "the redactions from the audio-video recordings and transcripts would not lead to confusion or undue speculation," id.; and that the petitioner actually "relied on his and Gallett's statements as a critical part of his defense" and "benefited from redactions in his own statements that would have contradicted his theory on defense," id. at 662. On appeal, the petitioner argues that the SJC erred in holding that the trial court did not violate Bruton when it allowed the jurors to read Gallett's redacted statements. In the petitioner's view, the SJC's decision was based on both an unreasonable determination of the facts and a misapplication of federal precedent. He directs our attention to a number of redacted statements, which he submits were "powerfully incriminating." These include the following:1 • Gallett's statement that, once the victim entered the abandoned house, he "starts like taking out the pizzas and asking [ ] to turn on the light." • Gallett's statement that, after he hit the victim in the neck, "[ ] ended up all the way into like the first room after the kitchen, in like this room, and like [the victim] still wasn't dead." 1We have indicated where the redactions in the transcript were located with the following symbol: "[ ]". - 25 - • Gallett's statement that, after he, Mathurin, and the petitioner took the victim's vehicle and drove to the church, "[ ] cleaned out the car, like all the stuff in it." • Gallett's statement that the "knife [he] used up there" is "gone," that he is "not sure" where it went, and that he "remember[s] [ ] cleaning it up." The SJC, the petitioner posits, made an unreasonable determination of the facts when it found that these redactions were not "facially" incriminating given that they did not obviously refer to the petitioner rather than Mathurin. This was unreasonable, the petitioner says, in light of the fact that Mathurin's name appeared unredacted in other parts of the transcript. Thus, "[a]ny reasonable juror" would have deduced that "[t]he court is not hiding Mathurin's name" and any redaction must be of the petitioner's name. In any event, the SJC — as the petitioner sees it — misapplied Gray when it reasoned that there was no Bruton violation given that "Gray makes no exception merely because a blank space could refer to multiple persons." The petitioner adds that Gray itself revolved around a redaction that could have referred to multiple individuals — yet the Supreme Court found that the redacted confession violated Bruton. - 26 - We have reviewed the state court trial record with care.

We conclude that the SJC's decision was based upon an unreasonable application of Gray.

Gray made clear that "[r]edactions that simply replace

a name with an obvious blank space or a word such as 'deleted' or a symbol or other similarly obvious indications of alteration . . . leave statements that, considered as a class, so

closely resemble Bruton's unredacted statements that, in our view, the law must require the same result." 523 U.S. at 192. This holds true even "if the juror hears the judge's instruction not to consider the confession as evidence against [the defendant]," id. at 193, and even when "the reference might not be transparent" like when "a confession . . . uses two (or more) blanks, even though only one other defendant appears at trial," id. at 194-95.

What is more, a Bruton violation occurs even when a redaction is

such that "the jury must use inference to connect the statement in this redacted confession with the defendant." Id. at 195.

The redactions here fall within the class that, Gray determined, "so closely resemble[s] Bruton's unredacted statements," id. at 192, and, thus, are "facially incriminating"

under Richardson, 481 U.S. at 211. This conclusion flows from the simple fact that the jury would have easily and immediately been able to infer that the redacted portions of Gallett's statements

- 27 - in the transcript referred to the petitioner rather than to

Mathurin. See Gray, 523 U.S. at 196. We explain briefly.

To begin, the redacted portions of Gallett's statements

in the transcript clearly included "obvious indications of alteration."2 Id. at 192. That these alterations consisted of deletions of multiples lines and passages and not just blank spaces

— facts that the Commonwealth contends precludes a determination

that the alterations were facially incriminating — is beside the point. What matters is that the redactions plainly indicate that

alterations have been made. These redactions would have led the jury quite readily to infer that the deletions referred to the petitioner. Given that it was Gallett's statement, the only other

option was that the deletions referred to Mathurin. Yet, Mathurin was not on trial. A juror would thus have likely reasoned that the most obvious person to whom the redactions were referring to was the petitioner. To cinch the matter, Mathurin's name appeared unredacted elsewhere in the transcript and, therefore, it would have been child's play for the jury to deduce that the redacted portions must refer to someone other than Mathurin. The This conclusion does not end our inquiry. Having found that the SJC unreasonably applied Gray, we next must determine whether its error resulted in "actual prejudice" and had a

"substantial and injurious effect or influence in determining the jury's verdict." Brecht, 507 U.S. at 631, 637.

In making this determination, our review is de novo.

Importantly, the SJC did not engage in a Brecht analysis. Thus — notwithstanding the deferential review mandated by AEDPA — "we can hardly defer to the state court on an issue that the state court did not address." Fortini v. Murphy, 257 F.3d 39, 47 (1st Cir.

2001).

- 29 - In undertaking a Brecht analysis, "[t]he burden of establishing harmlessness rests with the state qua respondent." Foxworth, 570 F.3d at 436. And if we "entertain[] 'grave doubt as to harmlessness, the petitioner must win.'" Id. (quoting O'Neal v. McAninch, 513 U.S. 432, 437 (1995)). The Commonwealth argues that the petitioner failed to show that the Brecht hurdle was cleared for three reasons. First, it suggests that "Gallett's statements, when read as a whole, recount only his own involvement in the crimes." Although it concedes that some of Gallett's statements "could have been construed to refer to [someone] else," it insists that none of these statements "directly implicate another individual in the commission of the robbery or murder." Second, the Commonwealth suggests that there was no Brecht error because the petitioner "used Gallett's confessions to advance his [own] defense." Third, it suggests that "there was overwhelming evidence supporting petitioner's convictions" and, thus, even if Gallett's redacted statements were improperly received in evidence, they did not have a substantial and injurious effect or influence in arriving at the jury's verdict. We start with the Commonwealth's second suggestion, which we find unpersuasive. We do not see how the petitioner's use of Gallett's statements in support of his own defense necessarily insulates those statements from the claim that they - 30 - had a prejudicial effect vis-à-vis the verdict. The Commonwealth offers no persuasive authority in support of its position, and we are not aware of any. Consequently, we reject this suggestion out of hand. This leaves the Commonwealth's first and third suggestions. The first suggestion — that none of the redacted statements directly implicates the petitioner in the commission of the robbery or murder — is literally correct. None of those statements explicitly singles out the petitioner as being the one who either robbed or murdered the victim. But to constitute a prejudicial Brecht error, the redacted statements need not directly link the petitioner to these crimes. All that they need to do is to have a "substantial and injurious effect or influence in determining the jury's verdict." Brecht, 507 U.S. at 631. The Commonwealth's first suggestion is, therefore, a dead letter. This brings us to the Commonwealth's final suggestion. That suggestion is built on bedrock: there was abundant evidence for the jury to find the petitioner guilty under either a theory of felony-murder or a theory of extreme atrocity or cruelty. But our finding that the SJC reasonably determined that there was sufficient evidence to convict the petitioner is not necessarily coterminous with the outcome of a Brecht analysis. See, e.g., Foxworth, 570 F.3d at 436. On this issue, we hold that the substantial evidence available obviated the possibility that - 31 - Gallett's redacted statements prejudiced the jury. Put another way, we entertain no grave doubt that the jury would have reached the same verdict even if it had not heard Gallett's redacted testimony. Of course, Gallett's redacted statement in which he asserted that he "remember[ed] [ ] cleaning [the knife] up" was arguably different in kind from his other redacted statements. The other redacted statements placed the petitioner in the abandoned house, in the room in which the victim died, and in the victim's vehicle. One of those statements further implicated the petitioner in cleaning up blood from the vehicle. And yet — in addition to the fact that there was a substantial amount of evidence in the record that already established these connections between the petitioner and the crime scene — none of these statements linked the petitioner to the murder. By contrast, Gallett's statement describing the petitioner cleaning the knife seemingly close in time and space to the murder may have insinuated just that. Even so, the assertion that this redacted statement prejudiced the petitioner stands on shaky ground. There was a substantial amount of other evidence in the record that already tied the petitioner to the murder. Valery's testimony established that the petitioner helped plan the heist and carried a knife on his person. The victim was stabbed repeatedly; a bent and broken - 32 - knife was found at the scene; the petitioner had the victim's blood on his clothes; and the petitioner had bleeding cuts on his hand shortly after the murder. See Gallett, 119 N.E.3d at 659-60. What is more, the petitioner himself told the doctors treating him in the emergency room that the injuries were caused by a knife. See id. In short, the petitioner was caught red-handed. The most that the petitioner's counsel could offer to blunt the force of this evidence was to point to the petitioner's shifting stories and evidence that there was some broken glass at the scene of the murder. He then speculated that the petitioner had acquired the wounds from breaking the glass to enter the scene (contrary to what the petitioner told the doctors). The dissent conjectures that, if indeed the glass were the true source of the cuts, the petitioner may have lied to the treating physicians to conceal his presence at the scene of the crime. But if the petitioner was intent on lying, it seems implausible that — knowing that the victim had died of stab wounds — he would have volunteered that a knife was the source of the cuts. All in all, this properly admitted evidence, by itself, left little room for any doubt that the petitioner stabbed the victim. Cf. Foxworth, 570 F.3d at 436 (holding that codefendant's redacted statement both violated Bruton and constituted Brecht error when other incriminating evidence was scarce and thus it was probable that redacted statement had substantial and injurious influence on outcome). - 33 - And because the jury was given a joint venturer instruction, it was not required to pick only one murderer. Then, too, Gallett's testimony was hardly a model of truthfulness. When it came to describing the knife, he offered wildly inconsistent testimony about who cleaned it and about who possessed it on the morning after the murder. In any event, whatever probative value Gallett's testimony might be said to have had, it was like coals to Newcastle. See Sinnott v. Duval, 139 F.3d 12, 20 (1st Cir. 1998) (finding no Brecht error in codefendant's improperly admitted testimony because that testimony "had to have fared poorly in the jury's minds"). The genius of the jury system is the ability of impartial jurors to make a common-sense appraisal of the evidence before them. The dissent's analysis posits a jury made up of remarkably gullible individuals. We think that almost any real-life jury would find guilt after taking into account the petitioner's role in planning a crime that would be easy to investigate if a live victim was left behind, the blood on the petitioner's clothes, his ownership of a knife, the cuts on his hands, his admission to the emergency room doctors, and his flimsy theory for why that admission was supposedly a lie. Viewed in light of the totality of the evidence in this case, we conclude that Gallett's statements did not have a "substantial and injurious effect or influence in determining the jury's verdict." Brecht, 507 U.S. at 631. It - 34 - follows inexorably that the SJC's application of Gray, though mistaken, does not warrant habeas relief. C The petitioner next argues that the SJC misapplied clearly established precedent when it held that the trial court committed only harmless error in refusing to allow him to cross- examine the Commonwealth's medical examiner about the location of the wounds on his hands. We set the stage. During the trial, the petitioner attempted to cross- examine the medical examiner about wounds on his right hand. After a detective testified that the petitioner had cuts on "the meaty side on the back of [his] right hand," "a laceration type injury on the heel near his wrist," and "on the knuckle," the petitioner's counsel asked the medical examiner, "If a person were wielding a knife and injured themselves on the knife that they were wielding, you would expect to see injuries to the interior of their palm; is that fair to say?" The Commonwealth objected, and the judge sustained the objection. At sidebar, the judge held firm, stating that she did not "think this witness [was] qualified to talk about the possible wounds that might be inflicted on knife wielders." The petitioner argued that the judge violated his confrontation rights by limiting his cross-examination of the medical examiner. The SJC acknowledged that "the judge should have permitted [the petitioner] to cross-examine the medical - 35 - examiner about theoretical wounds on [the petitioner's] hand," but determined that the petitioner was "unable . . . to demonstrate that he was prejudiced by the judge's ruling." Gallett, 119 N.E.3d at 665. In support, the SJC explained that, "the judge did not completely bar [the petitioner] from cross-examining the medical examiner about knife wounds," inviting the petitioner to present expert testimony about the cut to his hand if it was relevant. Id. The petitioner never did so. Moreover, the petitioner was allowed to present other evidence to demonstrate that he did not wield a knife. Id. The petitioner suggests that the SJC's decision was a misapplication of the Supreme Court's holding in Delaware v. Van Arsdall, 475 U.S. 673 (1986).3 He insists that a proper analysis of Van Arsdall requires a finding that he was prejudiced by the trial court's limitation on his cross-examination of the medical examiner. This suggestion does not move the needle. Van Arsdall is not on point. The issue before the Van Arsdall Court was whether a trial court's denial of a defendant's ability to engage in an "otherwise appropriate cross-examination designed to show a 3Although the SJC did not cite Van Arsdall, we find this omission inconsequential. See Zuluaga v. Spencer, 585 F.3d 27, 31 (1st Cir. 2009) ("[I]t would elevate form over substance to impose some sort of requirement that busy state judges provide case citations to federal law (or corresponding state law) before federal courts will give deference to state court reasoning."). - 36 - prototypical form of bias on the part of the witness" constituted a violation of the Confrontation Clause. Id. at 680. To be specific, the inquiry concerned whether a limitation on a defendant's ability to cross-examine a witness in order to impeach the witness prejudiced the defendant. See Brown v. Ruane, 630 F.3d 62, 70 (1st Cir. 2011) ("The Supreme Court's application of Van Arsdall has always involved evaluation of restrictions on cross-examination intended to impeach the credibility of the witness being examined."). Here, by contrast, the limitation on the cross-examination had nothing to do with impeaching or questioning the credibility of the medical examiner. Because Van Arsdall's prejudice analysis is inapposite, we do not see how the SJC's holding can be deemed to be "contrary to, or involve[] an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." 28 U.S.C. § 2254(d)(1); see Knowles v. Mirzayance, 556 U.S. 111, 122 (2009) ("[T]his Court has held on numerous occasions that it is not 'an unreasonable application of' 'clearly established Federal law' for a state court to decline to apply a specific legal rule that has not been squarely established by this Court."). We add, moreover, that the petitioner's claim that the SJC unreasonably applied federal precedent fails to withstand scrutiny when analyzed in light of relevant Supreme Court precedent. "Whether rooted directly in the Due Process Clause of - 37 - the Fourteenth Amendment or in the Compulsory Process or Confrontation clauses of the Sixth Amendment, the Constitution guarantees criminal defendants 'a meaningful opportunity to present a complete defense.'" Crane v. Kentucky, 476 U.S. 683, 690 (1986) (citations omitted) (quoting California v. Trombetta, 467 U.S. 479, 485 (1984)). As part of this meaningful opportunity, defendants enjoy the right to confront and cross-examine witnesses, see Chambers v. Mississippi, 410 U.S. 284, 295 (1973), and "elicit exculpatory defense evidence through cross- examination," Brown, 630 F.3d at 72. But this right "is not absolute and may, in appropriate cases, bow to accommodate other legitimate interests in the criminal trial process." Chambers, 410 U.S. at 295. Withal, "[t]his right is abridged by evidence rules that 'infring[e] upon a weighty interest of the accused' and are 'arbitrary' or 'disproportionate to the purposes they are designed to serve.'" Holmes v. South Carolina, 547 U.S. 319, 324- 25 (2006) (second alteration in original) (internal quotation marks omitted) (quoting United States v. Scheffer, 523 U.S. 303, 308 (1998)). Infringements on this right to present a complete defense are subject to a harmless-error standard. See Crane, 476 U.S. at 691. Given this legal landscape, we cannot say that the SJC's ruling "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme - 38 - Court of the United States." 28 U.S.C. § 2254(d)(1). As the SJC explained, even though the trial court erred, the petitioner was wholly unable to demonstrate that he was prejudiced by this error. See Gallett, 119 N.E.3d at 665. The petitioner was given ample opportunity to present his defense, including a chance to present his own expert testimony regarding the cut to his hand. See id. That he never sought to call such a witness does not render the trial court's error prejudicial. We therefore conclude that the SJC's ruling did not involve an unreasonable application of Supreme Court precedent. D The petitioner next argues that the SJC's finding of no error in the trial court's failure to provide various jury instructions departed from clearly established precedent and was based on an unreasonable determination of the facts. At issue is the trial court's failure to provide (1) a supplemental instruction regarding armed robbery, (2) a lesser included offense instruction for use of a motor vehicle without authority, and (3) a humane practice instruction. We consider these matters sequentially.^[4] At trial, the petitioner requested "that the judge instruct the jur[ors] that they 'must find that the required intent

to steal coincided with the use of force' to find him guilty of armed robbery and felony-murder. The judge declined to give the instruction, stating: 'I think it's inappropriate based on the state of [the] evidence . . . .'" Id. at 662 (second alteration in original). The SJC affirmed the trial court's refusal. See id. at 663. In the SJC's estimation, the trial court's

instructions regarding felony-murder with robbery serving as the predicate offense "as a whole, sufficiently explained to the jury that the Commonwealth was required to prove the defendant harbored an intent to steal at the same time he used force." Id. at 662.

The SJC explained that the trial court's instructions to the jury

— "that '[t]he actual force and violence must be the cause of the defendant obtaining possession of the property,' and that 'the Commonwealth must prove that the defendant took and carried away the property against the alleged victim's will with the intent to deprive the alleged victim of his possessions permanently'" — were

"located mere lines apart in the transcript." Id. (alteration in original). Owing to the fact that the instruction on felony- murder similarly conveyed that the Commonwealth had to prove that At trial, the petitioner requested that the jury be instructed on the use of a motor vehicle without authority as a lesser included offense of armed robbery. "The judge declined to give the instruction because she thought it was 'highly inappropriate when [there were] four alternative items that are alleged to have been stolen' and that the instruction did not fit with 'the facts and circumstances of this case.'" Gallett, 119

N.E.3d at 663 (alteration in original). The SJC affirmed this We reach a similar conclusion with respect to the petitioner's argument regarding the trial court's failure to provide a humane practice instruction. At trial, the petitioner requested such an instruction. See id. at 666. Although conceding that he "didn't raise [voluntariness] as an issue in the trial," the petitioner argued that he did not do so specifically because he believed that the video of his interrogation — in which he implicated himself in the crime — "spoke for itself, and [he] didn't need to ask more questions about it." Id. at 667

(alterations in original). The trial judge declined this request, - 44 - finding that the petitioner "chose not to make the voluntariness of [his] statement[] a live issue at trial." Id. at 666. The SJC affirmed this decision. "[T]he settled law in the Commonwealth is that 'if the voluntariness of the defendant's statements remains a live issue at trial, the judge must submit the issue of voluntariness to the jury.'" Id. at 668 (quoting Commonwealth v. Sunahara, 920 N.E.2d 831, 834 (2010)). But "[t]o be considered a live issue, 'substantial evidence of involuntariness [must be] produced.'" Id. (second alteration in original) (quoting Commonwealth v. Kirwan, 860 N.E.2d 931, 942 (2007)). Here, however, "the issue of voluntariness was insufficiently raised to require the judge to give a humane practice instruction." Id. In support, the SJC noted that the petitioner not only conceded that he did not raise voluntariness as an issue but also employed a theory of defense — that he neither participated in the victim's murder or robbery nor that he had the requisite intent — that "did not require a humane practice instruction" given that "his argument to the jury was that his interrogation statements were evidence that he was not culpable for the murder." Id. at 669. The petitioner argues that the SJC's decision denied him his "right to due process secured by the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and - 45 - violated Supreme Court precedent" and was based on an unreasonable determination of the facts. Not so. In support of his first claim, the petitioner again relies on Mathews, 485 U.S. at 63. Yet — as explained above — Mathews does not constitute clearly established federal precedent outside the context of entrapment. And to the extent that the petitioner argues that the failure to give a humane practice instruction constituted an independent due process violation, his argument falls flat. As the SJC explained, such an instruction is required (as a matter of state law) only "if the voluntariness of the defendant's statements remains a live issue at trial" and "'substantial evidence' of involuntariness was produced." Gallett, 119 N.E.3d 668 (quoting Kirwan, 860 N.E.2d at 942). Since the SJC reasonably concluded that the facts of the case did not render voluntariness a live issue, we have little difficulty in concluding that its determination regarding the refusal to grant a humane practice instruction was not unreasonable. And given that the facts amply demonstrate that voluntariness was not a live issue, we conclude that the SJC's decision was not based on an unreasonable determination of the facts. To sum up, we hold that none of the SJC's rulings concerning the petitioner's claims of instructional error constitute grounds for federal habeas relief. - 46 - E The petitioner's final plaint stems from the trial court's statement to the jury on September 11, 2014, in which it acknowledged the anniversary of September 11, 2001. Before the SJC, the petitioner argued that the trial court's statement prejudiced him. The SJC demurred, finding no prejudicial error. See id. at 664. In this court, the petitioner asserts that the SJC's decision was contrary to and an unreasonable application of clearly established federal precedent. As the SJC observed, the trial judge addressed the jury to acknowledge the anniversary of September 11, 2001. See id. The judge told the jury that, on September 11, 2001, she had presided over a trial and was forced to evacuate the courthouse that day. Still, she was moved when the jurors in the 2001 case "all voted unanimously to come back the very next day." Id. After relaying this story to the jury she had empaneled, the judge stated, I just wanted to share that story with you because I'm sure you'll appreciate you're part of the government here, and the government did go on and has continued to go on and you are the government here. So I wanted to share that story with you and hope you further appreciate your vital role in our justice system here in the Commonwealth of Massachusetts and the United States of America. Id. - 47 - In finding that this statement did not prejudice the petitioner, the SJC explained that, although it was "mindful that the 'effect on the jury of whatever a judge says or does may be significant,'" id. (quoting Commonwealth v. Fitzgerald, 406 N.E.2d 389, 395 (1980)), in this instance there was no prejudice because "the judge's remarks were made to emphasize the importance of jury duty. Her reference that the jury were part of the government was cursory and nonprejudicial." Id. The SJC added that "because the judge's remarks were neither intemperate nor critical of the attorneys, there was no danger that the judge exhibited to the jury a bias against the defendant." Id. (quoting Commonwealth v. Mello, 649 N.E.2d 1106, 1118 (1995)). The petitioner complains that the SJC's holding violated his due process and fair trial rights, including his right to a fair trial. In support, he cites to Gray v. Mississippi, 481 U.S. 648, 667 (1987), asserting that Gray establishes that "an impartial jury is so basic to a fair trial that its infraction can never be treated as harmless." This complaint lacks force. Although the Gray Court recognized that the right to an "impartial adjudicator, be it judge or jury," is "'so basic to a fair trial that [its] infraction can never be treated as harmless error,'" the facts of that case render it inapposite here. Id. at 668 (quoting Chapman v. California, 386 U.S. 18, 23 (1967)). Gray concerned whether the impermissible - 48 - exclusion of a prospective juror in a capital case could be subject to harmless error review. See id. at 651. Because nothing resembling such an issue arises in the case at hand, we find Gray to be of little relevance. On the facts here, we hold that the SJC reasonably concluded that the judge's remarks — when read in context — were merely intended to emphasize the importance of jury duty. Consequently, the SJC was not unreasonable when it held that the trial court's remark "was cursory and nonprejudicial." Gallett, 119 N.E.3d at 664. III We need go no further. We hold that the SJC's decision affirming the petitioner's conviction was neither contrary to clearly established federal law nor did it involve an unreasonable application of clearly established federal law. Similarly, we hold that the SJC's decision did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence presented at the trial court. It follows that the district court did not err in declining to issue a writ of habeas corpus. - 49 - For the reasons elucidated above, the judgment of the district court is Affirmed. —Dissenting Opinion Follows— - 50 - BARRON, Chief Judge, concurring in part and dissenting in part. Michel St. Jean is serving a life sentence in a Massachusetts state prison for his state law convictions for felony murder and murder in the first-degree by reason of extreme atrocity or cruelty. He petitions for federal habeas relief based, in part, on the use of a confession by his co-defendant, Alexander Gallett, at his Massachusetts state court criminal trial on the underlying charges.^[6] St. Jean contends that under Bruton v. United States, 391 U.S. 123 (1968), and precedents applying it, his federal constitutional right as a criminal defendant to "be confronted with the witnesses against him," U.S. Const. amend. VI, was violated by the Commonwealth's use of Gallett's confession at trial. The Supreme Judicial Court of Massachusetts (SJC) held that there was no Sixth Amendment violation. See Commonwealth v. Gallett, 119 N.E.3d 646, 661 (Mass. 2019). The majority agrees with St. Jean, as do I, that, because of the reasons that the SJC gave for its Sixth Amendment ruling, we need not defer to it. The majority also agrees with St. Jean, as do I, that, reviewing de novo, the Commonwealth's use of Gallett's confession at St. Jean's criminal trial violated the Sixth Amendment because, by providing an eyewitness narration of St. Jean's conduct on the night of the crimes, it inculpated him