APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. George A. O'Toole, Jr., U.S. District Judge]

Before

Barron, Chief Judge, Lipez and Rikelman, Circuit Judges.

Cathryn A. Neaves for petitioner-appellant.

Tara L. Johnston, Assistant Attorney General, Criminal Bureau, with whom Andrea Joy Campbell, Attorney General of Massachusetts, was on brief, for respondent-appellee.

March 18, 2026

Page 2LIPEZ , Circuit Judge . Three decades after a fatal shooting in a Boston park, petitioner Rodolfo Carr was convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. In this habeas case, filed pursuant to 28 U.S.C. § 2254, Carr seeks dismissal of the indictment against him, claiming a violation of his Sixth Amendment right to a speedy trial. Carr also asserts an ineffective-assistance-of-counsel claim, arguing that his trial and appellate attorneys failed to develop and present evidence crucial to his speedy-trial claim. After careful consideration of the record and caselaw -- including our binding precedent on when the speedy-trial clock begins to run under federal law -- we agree with the district court that Carr is not entitled to habeas relief.

The district court did no independent factfinding, and we therefore review its denial of Carr's habeas petition de novo. See, e.g., Hudson v. Kelly, 94 F.4th 195, 200 (1st Cir. 2024). Like the district court, we review with deference the facts underlying the petition as determined by the Massachusetts Supreme Judicial Court ("SJC"). See, e.g., Martinez v. Salisbury, 158 F.4th 101, 103 (1st Cir. 2025).¹ Pursuant to federal statute, the Page 3state courts' factfinding is presumed correct "unless the petitioner rebuts this 'presumption of correctness' with 'clear and convincing evidence.'" Yeboah-Sefah v. Ficco, 556 F.3d 53, 66 (1st Cir. 2009) (quoting 28 U.S.C. § 2254(e)(1)); see also Watson v. Edmark, 118 F.4th 456, 459 (1st Cir. 2024).²

Although Carr asserts that the SJC made an unreasonable determination of the facts, he does not dispute the historical facts found by the SJC. Rather, he argues that the court erred in assessing the legal significance of the facts before it (his speedy-trial claim) and that his attorneys failed to provide the state courts with all relevant facts (his ineffective-assistance claims). Put differently, Carr challenges the significance of the Page 4facts found -- and omitted -- from the SJC's decision but does not identify error in the factual findings themselves.

We begin with the facts of the murder, as reported by the SJC:

Based on the evidence admitted at trial, the jury could have found the following. On August 5, 1974, the defendant, then twenty years old, and the victim, who was fourteen years old, were involved in a physical altercation near a park on Dudley Street in the Roxbury section of Boston. The defendant, who lived across the street from the park, waited near a light pole along the third base line of the park's baseball field until the victim returned to the park. The defendant then retrieved a long rifle with a scope that he had hidden in some nearby bushes. Carlos Carrasquillo, the victim's cousin, was playing baseball when he saw the defendant aim the gun at his cousin. Carrasquillo yelled, "[R]un. He is going to shoot you." The defendant, kneeling on the ground, aimed and shot the victim in the head.

The defendant ran from the park with the rifle in his hand. A group of bystanders carried the victim to an automobile and drove him to Boston City Hospital. He died eleven days later . . . . On the day of the shooting, police recovered a rifle with a scope from bushes in the rear yard of a house near the park. Witnesses to the shooting, who testified that they were familiar with the defendant, . . . thereafter never saw the defendant in the park.

Commonwealth v. Carr, 986 N.E.2d 380, 387 (Mass. 2013) (alteration in original). A murder complaint issued against Carr on AugustPage 5 17, 1974 -- roughly two weeks after the shooting and the day after the victim died. Id.

The SJC described at length the circumstances following the crime that are the focus of Carr's speedy-trial claim. We again rely on the SJC's recitation of the facts, albeit in summary form.

By September 1974 --within a month after the shooting -- Carr was in East Chicago, Indiana, where he was arrested and charged for robbery under the alias Michael Sloane. Id. He also gave the East Chicago police another alias -- Ivan Santa -- but they learned that he was being sought for a murder in Massachusetts. Id. Boston authorities were notified that Carr was being held in Indiana, and they planned to obtain an indictment against him at that time. Id. at 387-88. Although they sent the East Chicago police a murder warrant seeking his return to Massachusetts, they later decided to delay indicting Carr until after the East Chicago charge was resolved. Id. at 388. However, after a jury acquitted Carr of the robbery charge in March 1975, he was mistakenly released without notice to Boston authorities. Id. 3 From that time until 1994, "[t]here is no evidence that the Page 6Commonwealth [of Massachusetts] knew of the defendant's location or undertook any efforts to locate him." Id.

The SJC reported that, between 1975 and 1994, Carr "was charged in Illinois and Indiana with four different drug crimes under four different names," id., but the court gave no further details of Carr's activities during those nearly two decades. Then, when evaluating his speedy-trial claim, the SJC noted that "[t]he record before us does not disclose whether the Commonwealth acted with diligence in searching for the defendant, and the defendant, who has the burden of proving prejudicial delay sufficient to warrant dismissal, does not suggest such a lack of diligence." Id. at 390-91.⁴

As we will discuss below, Carr focuses in this appeal on the facts missing from the record presented to the SJC about his Page 7life between 1975 and 1994. Carr states that, from 1975 to 1984, he worked at an East Chicago company under his own name; from 1977 to 1981, he took classes at Purdue University, also using his own name; and he applied for a social security card under his own name during this period. Although acknowledging that he at times used aliases when detained by authorities during those years, he states that he used his own name at least twice when arrested. In short, as described by Carr, he "liv[ed] for . . . nearly a generation, under his own name, in the exact same place where Boston Police knew he was in 1974-1975." Memorandum of Law in Support of Petition for Writ of Habeas Corpus at 14-15, Carr v. Medeiros, No. 1:15-cv-12958 (D. Mass. July 6, 2021), Dkt. No. 80 ["Habeas Memorandum"] .

The SJC described the Boston Police Department's reengagement with Carr as follows:

In 1994, Boston police learned that the defendant was again in the custody of the Indiana department of correction. Two Boston police detectives traveled to an Indiana prison and interviewed the defendant concerning the 1974 shooting. The defendant maintained that he was not the man they sought, told police his name was Ivan Santa, and claimed that he had never been to Boston. On February 12, 1996, Boston police informed authorities in the Indiana department of correction that the defendant was still wanted for murder in Massachusetts, and provided them

Page 8with the murder warrant to serve as a detainer.

Carr, 986 N.E. 2d at 388. Carr subsequently waived extradition and was brought back to Massachusetts in April 1997. Id. He was indicted for murder in May 1997 and convicted in December 2004. Id. at 386, 388.

During the seven years between Carr's indictment and trial, while represented by a succession of attorneys, Carr filed several motions seeking to dismiss the murder indictment based on the violation of his speedy-trial rights. See id. at 388 n.2. The motions, all unsuccessful, focused on different time periods -- the first on the delay between 1974 and 1997, the second on the delay between 1994 (when he was interviewed by Boston authorities) and his indictment in 1997, and the third on the delay between his indictment and trial. Id. 5 Although Carr challenged the delay in his prosecution through these motions, the SJC found Page 9that he did not assert his right to a speedy trial until he filed a motion for a speedy trial in May 2004, "some seven years after his indictment, and ten years after Boston police interviewed him in Indiana in connection with the shooting." Id. at 391-92.

As stated above, a jury found Carr guilty of first-degree murder, and he was sentenced to life in prison.

Carr unsuccessfully appealed his conviction to the SJC, pressing claims for the violation of his constitutional right to a speedy trial and ineffective assistance of counsel, among other challenges to his prosecution and trial. See id. at 386.⁶ In its decision, the SJC applied the longstanding four-part balancing test for evaluating a Sixth Amendment speedy-trial claim that was set forth by the Supreme Court in Barker v. Wingo, 407 U.S. 514, 530-33 (1972). See Carr, 986 N.E.2d at 389-93. Under that framework, as the SJC explained, courts must consider "(1) the Page 10length of the delay [before trial]; (2) the reason for the delay; (3) the defendant's assertion of his right to a speedy trial; and (4) prejudice to the defendant." Id. at 389 (citing Barker, 407 U.S. at 530). The SJC readily concluded that the first factor -- the length of the delay -- "weigh[ed] heavily" in Carr's favor because, under Massachusetts law, the relevant timeframe was the thirty years between issuance of the murder complaint in 1974 and trial in 2004. Id. The SJC described that delay as "extraordinary." Id.

To assess the second factor -- the reason for the delay -- the SJC divided the thirty-year timespan into three segments: (1) the brief period from 1974 to 1975, when Boston authorities knew Carr was incarcerated in Indiana on the robbery charge; (2) "the twenty-two-year period from 1975 until the defendant's return to Massachusetts in 1997; and [(3)] the seven-year period between his indictment in 1997 and his trial in 2004." Id. at 389-90. However, neither in his appeal to the SJC nor in his habeas petition did Carr argue that the delay from 1997 to 2004 should be weighed in his favor. See id. at 391; Habeas Memorandum, at 3. Likewise, Carr has not argued to us that the 1974-75 period is material to his speedy-trial claim. Rather, he maintains that "the critical time frame" is the nineteen years "from 1975, when [he] was acquitted in East Chicago, Indiana, [to] 1994, when Boston Police went out to Indiana to interview [him]."Page 11 We thus consider only that nineteen-year delay as pertinent to this appeal. For those years, 7 the SJC ultimately concluded that, despite the lack of evidence showing efforts by Boston authorities to find Carr, the delay "d[id] not weigh against the Commonwealth" because Carr's "use of aliases with authorities in the Midwest, and his assertion of a false identity to Boston police [in 1994], permit the inference that he was attempting to evade prosecution for the shooting during this period." Carr, 986 N.E.2d at 391.

The SJC weighed the third factor -- assertion of the speedy-trial right -- "heavily" against Carr because he did not seek a speedy trial until 2004, "some seven years after his indictment" and a decade after Boston authorities questioned him about the murder in Indiana. Id. at 391-32. On the final factor -- prejudice to the defendant -- the SJC presumed that Carr suffered prejudice, id. at 392, but concluded, "after having weighed the Barker factors, that the defendant's constitutional right to a speedy trial was not violated," id. at 393. The SJC similarly rejected Carr's ineffective-assistance-of-counsel claim.⁸

Page 12In January 2014, after the SJC affirmed his conviction, Carr filed a pro se motion for a new trial in Superior Court. The motion was denied, and Carr petitioned unsuccessfully to obtain review of that denial by the full SJC. He then turned to the federal courts.

In July 2015, Carr filed the habeas petition that underlies this appeal. Among other contentions, he asserted that the SJC had wrongly rejected his Sixth Amendment speedy-trial and ineffective-assistance-of-counsel claims, including, with respect to the latter, that his appellate attorney had failed to raise a "speedy trial claim." See Petition for Habeas Corpus at 2-3, Carr, No. 1:15-cv-12958 (D. Mass. July 15, 2015), Dkt. No. 1. Later, at Carr's request, the district court granted a stay of the petition so Carr could exhaust the specific ineffective-assistance claims that are now before us: (1) his trial counsel's failure to develop and present the evidence described above showing that he was living openly under his own name for most of the time between 1975 and 1994, and (2) his appellate counsel's failure to raise trial counsel's ineffectiveness in that respect -- deficiencies that Page 13Carr claimed significantly damaged his ability to show a speedytrial violation. After the state courts rejected Carr's motion for a new trial raising those claims, he returned to federal court and moved to amend his habeas petition to include the newly exhausted claims. The district court held a hearing on the motion and granted it, but the court also issued a decision that same day denying habeas relief.⁹

On the speedy-trial claim, the district court held that the SJC's assessment of the record -- "'indicat[ing] that Carr did not want a speedy trial'" -- was "supported by a reasonable application of Sixth Amendment jurisprudence." Carr v. Lizotte, No. 15-12958, 2024 WL 3677929, at *2 (D. Mass. July 16, 2024) (citation modified) (quoting Carr, 986 N.E.2d at 393). On the ineffective-assistance claims, the district court similarly concluded that "[t]he Commonwealth's courts . . . properly applied the relevant legal standard in rejecting Carr's . . . arguments." Id. The court thus denied Carr's habeas petition.

We subsequently granted a certificate of appealability Page 14limited to the speedy-trial claim and the related claims of ineffective assistance by Carr's trial and appellate attorneys.¹⁰

The speedy-trial and ineffective-assistance claims that Carr brings to us confront significant threshold barriers. For the speedy-trial claim, the SJC analyzed the delay using the Supreme Court's four-part Barker v. Wingo inquiry, see Carr, 986 N.E.2d at 389, but it relied on Massachusetts law in determining that the clock began to run when the murder complaint was issued in 1974, see id. 11 The federal clock, however, differs from the state clock. Our precedent "hold[s] that a Massachusetts criminal complaint, standing alone, is not the public, official accusation that the Sixth Amendment requires." Butler v. Mitchell, 815 F.3d 87, 90 (1st Cir. 2016); see also Rashad v. Walsh, 300 F.3d 27, 3536 (1st Cir. 2002) (holding that "the preferment of charges" in a Page 15Massachusetts complaint did not start the speedy-trial clock). Rather, under federal law, "the speedy-trial right attache[s], and the count beg[ins], not when the complaint was issued, but when the . . . indictment was announced." Butler, 815 F.3d at 89.¹² If Rashad and Butler apply here, the only relevant period of delay for Carr's Sixth Amendment speedy-trial claim would be the seven years from Carr's indictment in 1997 to his trial in 2004.¹³

Meanwhile, the threshold hurdle for Carr's ineffective-assistance claims arises from the complex procedural default rules that limit the availability of habeas relief in federal court. See, e.g., Lee v. Corsini, 777 F.3d 46, 54-58 (1st Page 16Cir. 2015). According to the government, those rules bar us from considering the deficiencies in representation on which Carr now relies to claim constitutionally ineffective performance by his attorneys with respect to his speedy-trial claim. The government maintains that Carr raised those concerns in state court too late and cannot make the required showing of cause and prejudice to overcome that default. See id. (explaining the relevant procedures under Massachusetts law and the impact of procedural default on federal habeas review).

As we shall explain, Carr cannot surmount the threshold barrier to his speedy-trial claim and, because his ineffectiveassistance-of-counsel claims fail on their merits, we need not delve into the issue of procedural default.

Carr acknowledges that our precedent on the running of the speedy-trial clock under federal law, which governs his Sixth Amendment claim, presents a problem for him. He asks us to reconsider Rashad and Butler, but that is a step we may not take as a panel. See, e.g., United States v. Perez, 89 F.4th 247, 250 (1st Cir. 2023) ("Under the law of the circuit doctrine, newly constituted panels must follow the rulings of preceding panels that are 'directly (or even closely) on point . . . .'" (quoting United States v. Guzman, 419 F.3d 27, 31 (1st Cir. 2005))). Evidently anticipating that we would adhere to our court's prior Page 17rulings, Carr alternatively argues that we should not treat the indictment as the trigger for the speedy-trial clock given the facts of this case. He argues that a "Wanted Poster" naming him as a suspect, which was circulated shortly after the 1974 shooting, should be viewed in combination with the complaint to establish "the public, official accusation that the Sixth Amendment requires." Butler, 815 F.3d at 90.

In Rashad, where we first addressed whether a Massachusetts complaint or a later-filed indictment "wound the constitutional clock," 300 F.3d at 35, we concluded that Supreme Court precedent left "no doubt that only a 'public accusation' animates the right to a speedy trial," id. at 36 (quoting United States v. Marion, 404 U.S. 307, 321 (1971)). Importantly, we then stated that, "[c]onsistent with this approach, the case law suggests that, in the absence of either an indictment or an information, 'only the actual restraints imposed by arrest and holding to answer a criminal charge' engage the speedy trial right." Id. (emphasis added) (quoting United States v. Loud Hawk, 474 U.S. 302, 310 (1986)).

Based on this assessment of the law, we concluded that the date of the rape complaint against petitioner Rashad was "irrelevant for speedy trial purposes" "[b]ecause the preferment of charges [in the complaint] was unaccompanied by any public accusation or act of detention." Id. (emphasis added); see also Page 18id. at 31 (identifying the charged crime). Then, in Butler, we described the needed step as one that "commence[s] the prosecutorial process in earnest," and we adhered to our prior conclusion that "a Massachusetts criminal complaint, standing alone," does not suffice. Butler, 815 F.3d at 90.

Carr argues that, with inclusion of the police circular naming him -- the "Wanted Poster" -- the record here contains more than the complaint "standing alone," and the additional element -- the "Wanted Poster" -- provides the "public accusation" that we found lacking in Rashad and Butler. We disagree.

We do not doubt that a "Wanted Poster" may result in more public awareness that an individual is the target of a criminal investigation than would a complaint on its own. In Rashad, however, we exemplified the "'public accusation' [that] animates the right to a speedy trial" with reference to an indictment or information -- the two formal charging methods that we said would trigger the speedy-trial clock for a non-detained individual. 300 F.3d at 36 (quoting Marion, 404 U.S. at 321). The notion of a formal charging document appears repeatedly in the Supreme Court's speedy-trial cases. See, e.g., Betterman v. Montana, 578 U.S. 437, 441 (2016) (noting that "[t]he Sixth Amendment's Speedy Trial Clause homes in on the . . . period[] from arrest or indictment through conviction," and that the constitutional right to a speedy trial "does not attach Page 19until . . . a defendant is arrested or formally accused" (emphasis added)); Doggett v. United States, 505 U.S. 647, 654-55 (1992) (noting "the principle . . . that the Sixth Amendment right of the accused to a speedy trial has no application beyond the confines of a formal criminal prosecution" and is "triggered by arrest, indictment, or other official accusation" (emphases added)).

The police circular naming Carr is plainly not an official, formal accusation. And a "Wanted Poster" neither transforms the complaint into a more formal charging document nor moves "the prosecutorial process" to a stage beyond that achieved by the complaint itself. Butler, 815 F.3d at 90. Put differently, any public awareness of criminal charges generated by a "Wanted Poster" does not stem from the sort of formal "public accusation" that Rashad and Butler set as a requirement for starting the speedy-trial clock -- and that we found unfulfilled by the complaint alone.

In sum, we see no rationale for concluding that the police circular changed the status of the prosecution against Carr such that the circumstances here fall outside the scope of Rashad and Butler. For the purpose of Carr's habeas petition, therefore, the speedy-trial clock started in 1997, when he was detained and indicted for the murder charge.¹⁴ However, as we have recounted, Page 20Carr made no argument to the SJC -- let alone to us -- that the seven-year delay from indictment to trial violated his constitutional right to a speedy trial. See supra Section I.E.1.¹⁵ Accordingly, any such claim is unequivocally waived.

As we have described, Carr blames his trial attorney for failing to bolster the pretrial motion to dismiss that covered the relevant nineteen-year delay with evidence that he was living under his own name for most of the period between his departure from Massachusetts in 1974 and his interview with the Boston authorities twenty years later. And he complains that his appellate counsel provided constitutionally deficient advocacy when the attorney failed to invoke trial counsel's deficient performance on that speedy-trial claim in the appeal to the SJC.

Page 21The government argues that we should not reach the merits of the ineffective-assistance claims because they were procedurally defaulted and thus foreclosed from habeas review. See generally Lee, 777 F.3d at 54-58. However, as the district court observed, the issue of procedural default is not straightforward on the record before us. See Carr, 2024 WL 3677929, at *2. Accordingly, like the district court, see id., we choose to bypass the complexities of the threshold issues because Carr's ineffective-assistance claims are unavailing on the merits. See, e.g., Yeboah-Sefah, 556 F.3d at 68 n.6 (similarly finding no need to resolve a procedural default dispute in a habeas case).¹⁶

With respect to Carr's Sixth Amendment speedy-trial Page 22claim, Carr's contentions offer no possibility of obtaining habeas relief on the ground that he was denied effective legal assistance. The deficiencies Carr cites are relevant only to a period of delay that we have excluded from his federal speedy-trial claim. Thus, even if we were to find "a reasonable probability that, but for counsel's unprofessional errors," the SJC might have weighed the delay between 1975 and 1994 more favorably for Carr, Strickland v. Washington, 466 U.S. 668, 694 (1984); see also id. at 687 (setting forth the two-pronged inquiry for ineffective-assistance-ofcounsel claims), that changed assessment would have no impact on the federal speedy-trial claim before us. As we have explained, under the Sixth Amendment, those years play no role in determining whether Carr was denied a speedy trial.

However, Carr's contentions of ineffective assistance are relevant to his assertion that the SJC improperly rejected his speedy-trial claim under Massachusetts law. As recounted above, under the Massachusetts constitution, the speedy-trial clock was triggered by issuance of the complaint in 1974, and the state-law speedy-trial claim therefore encompasses the period from 1975 to 1994. If "unprofessional errors" by his trial or appellate counsel resulted in Carr's loss of relief to which he was entitled under Massachusetts law, id. at 694, he would have a viable claim that his Sixth Amendment right to effective legal representation was violated. See, e.g., Miranda v. Kennedy, 125 F.4th 23, 31-32 (1st Page 23Cir. 2025) (in a federal habeas case, analyzing a Sixth Amendment claim premised on assertions of deficient performance affecting petitioner's culpability under state law); Ayala v. Alves, 85 F.4th 36, 53 (1st Cir. 2023) (analyzing ineffective-assistance claim based on trial counsel's handling of evidentiary issues in state trial).

Under Strickland's two-pronged test for evaluating claims of ineffective assistance of counsel, a petitioner must show both deficient performance by his attorneys and resulting prejudice to obtain relief. See Strickland, 466 U.S. at 700; see also Torres-Estrada v. United States, 122 F.4th 483, 494 (1st Cir. 2024). We have observed multiple times that "[t]he petitioner bears a heavy burden on each prong." Torres-Estrada, 122 F.4th at 494 (quoting Casey v. United States, 100 F.4th 34, 42 (1st Cir. 2024)).

Carr is unable to satisfy either prong of the Strickland inquiry with respect to his state-law speedy-trial claim. The "high bar" set by Strickland's performance prong reflects the Supreme Court's recognition that "[a] defense lawyer navigating a criminal proceeding faces any number of choices about how best to make a client's case." Buck v. Davis, 580 U.S. 100, 118 (2017). To demonstrate deficient performance, therefore, the defendant must show that "the lawyer's errors were 'so serious that counsel was not functioning as the "counsel" guaranteed . . . by the Sixth Page 24Amendment.'" Id. at 118-19 (omission in original) (quoting Strickland, 466 U.S. at 687).

In affidavits submitted as part of Carr's 2017 motion for a new trial in Massachusetts Superior Court, Carr's trial and appellate attorneys explained that they did not dwell on the evidence of his living openly during most of the period from 1975 to 1994 because they believed they had enough other evidence of the government's lack of diligence to support the speedy-trial claim.¹⁷ Carr may be correct that the "decision[] to leave Page 25unexplained the full picture of Mr. Carr's life . . . from 1975 to 1994[] resulted in Mr. Carr's use of aliases when arrested being used as 'low-hanging fruit' by the Commonwealth to justify" the delay in prosecuting him. Habeas Memorandum, at 20. Yet, "the proper standard for attorney performance is that of reasonably effective assistance." Strickland, 466 U.S. at 687. We cannot characterize the judgments made by Carr's attorneys as "so patently unreasonable that no competent attorney would have made [them]." Torres-Estrada, 122 F.4th at 494 (quoting Watson v. United States, 37 F.4th 22, 28 (1st Cir. 2022)).

As described above, the attorneys' affidavits show that they were aware that Carr used his own name for his schooling and in other contexts -- and, indeed, the record before the SJC contained some of that evidence 18 -- but each attorney determined that it would be sufficient to emphasize the other favorable evidence pertinent to the Strickland inquiry See supra note 17. Even if one could characterize as a misjudgment the choice to rely on the Commonwealth's lack of diligence and the prejudice to Carr, without highlighting his open living between 1975 and 1994, those Page 26determinations were far from "patently unreasonable" in the context of the entire record. Torres-Estrada, 122 F.4th at 494 (quoting Watson, 37 F.4th at 28). Carr's repeated use of aliases when interacting with law enforcement -- and particularly his insistence that he was not Rodolfo Carr when confronted by Massachusetts authorities in 1994 -- necessarily diminished the impact of his using his own identity at other times. Given the mixed record on Carr's behavior, any miscalculation in choosing which facts to highlight was simply not an "error[] so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment." Strickland, 466 U.S. at 687; see also Casey, 100 F.4th at 42 ("To give the required deference to counsel's choices, we strongly presume that the attorney has rendered adequate assistance and made all significant decisions in the exercise of reasonable professional judgment." (citation modified) (quoting Strickland, 466 U.S. at 690)).

The record also undermines Carr's effort to satisfy the prejudice prong of the Strickland inquiry. Carr must demonstrate a reasonable probability that, if the SJC had before it -- in Carr's words -- "the full picture of [his] life" during the relevant nineteen years, the court would have found a speedy-trial violation under Massachusetts law. See Strickland, 466 U.S. at 694. As we have noted, however, the trial record already included Page 27evidence that Carr had used his own name in a variety of contexts, 19 and the SJC remarked on the absence of evidence that Boston authorities had attempted to track him down during the years in question. See Carr, 986 N.E.2d at 390-91. In effect, the court discounted the significance of these favorable facts in light of Carr's use of aliases in his interactions with law enforcement authorities -- including in the 1994 interview in which he "denied both that his name was Rodolfo Carr and that he had ever been to Boston." Id. at 390.²⁰

In addition, we cannot conclude that more evidence concerning Carr's day-to-day life between 1975 and 1994 would have changed the court's view of Carr's failure to invoke his speedy-trial right under state law until shortly before trial -- which the court weighed "heavily" against him -- or the importance the court gave to the prejudice factor in the Barker framework . Carr, 986 N.E.2d at 392-93. Although the court Page 28presumed prejudice under the Barker framework from the lengthy delay, it noted within its speedy-trial analysis that it rejected Carr's separate argument that he was entitled to dismissal of the indictment based on the loss of evidence because "the prejudicial effect of such lost evidence was speculative at best." Carr, 986 N.E.2d at 392 n.4. The court also observed that "prejudice . . . 'cannot alone carry a Sixth Amendment claim,' and is only 'part of the mix of the relevant facts.'" Id. at 392 (quoting Doggett, 505 U.S. at 656). We thus see no "reasonable probability" that more attention by his trial and appellate attorneys to Carr's use of his own name would have resulted in a different outcome for the SJC's assessment of the Barker factors for the purposes of the state-law speedy-trial right. Strickland, 466 U.S. at 694.

In sum, even giving Carr the benefit of de novo review for his ineffective-assistance claims -- the most favorable review available -- those claims are unavailing. Accordingly, finding no basis for disturbing his conviction, we affirm the denial of Carr's petition for habeas relief.