In the

    United States Court of Appeals
                 For the Seventh Circuit
                     ____________________
No. 23-2690
GRANT GAMBAIANI,
                                                Petitioner-Appellant,
                                 v.

BRITTANY GREENE, Warden,
                                               Respondent-Appellee.
                     ____________________

         Appeal from the United States District Court for the
           Northern District of Illinois, Eastern Division.
          No. 1:21-cv-05142 — Thomas M. Durkin, Judge.
                     ____________________

       ARGUED APRIL 3, 2025 — DECIDED MAY 13, 2025
                ____________________

   Before HAMILTON, BRENNAN, and SCUDDER, Circuit Judges.
    BRENNAN, Circuit Judge. Grant Gambaiani was sentenced
to 34 years in prison after an Illinois jury found him guilty of
a host of crimes, including the repeated sexual assault of D.G.,
his minor cousin. Gambaiani appealed his conviction, argu-
ing the trial court violated his Sixth Amendment right to a
public trial when it partially closed the courtroom during
D.G.’s testimony. The Illinois Appellate Court disagreed,
2                                                    No. 23-2690

affirmed his conviction, and the Supreme Court of Illinois de-
nied review.
    Gambaiani then sought postconviction relief in the Illinois
state courts, averring his original trial attorneys failed to pro-
vide him with effective assistance during plea negotiations.
He argued they did not properly apprise him of his sentenc-
ing exposure and, as a result, he rejected a plea offer he might
otherwise have accepted. The state courts refused to grant
Gambaiani relief.
    He then filed a petition for a writ of habeas corpus under

 in federal district court, claiming violations
of his constitutional rights to a public trial and to effective as-
sistance of counsel. The court denied his petition. Gambaiani
appeals, and we affirm.
                         I. Background
    A. Factual Background
    The underlying facts of this case are disturbing. Gam-
baiani—at the time 24 years old—repeatedly abused his 10-
year-old cousin, D.G. He touched D.G.’s genitals and
instructed D.G. to do the same to him, assuring his minor
cousin this was all normal. Gambaiani anally penetrated and
performed oral sex on D.G. And he described to his cousin
various other sexually deviant activities he hoped to pursue
with him. In addition to abusing D.G., Gambaiani also pos-
sessed pornographic videos depicting minors.
    For his actions, the State of Illinois charged Gambaiani
with four counts of predatory criminal sexual assault of a
child, one count of aggravated criminal sexual abuse of a mi-
nor, and a final count of manufacturing child pornography. In
July 2009, the state offered him a deal: He could plead guilty
No. 23-2690                                                    3

to a single felony in exchange for a sentencing range of 4 to 15
years’ imprisonment. After discussing the offer with his attor-
neys, Kevin Halverson and Elliot Samuels, Gambaiani
rejected it. According to Gambaiani, this was because his at-
torneys led him to believe he would not have to serve any
prison time.
   In truth, each of his predatory criminal sexual assault
charges alone carried a sentence of 6 to 60 years, and in the
event of multiple convictions, Gambaiani faced mandatory
consecutive sentences. His attorneys claimed to have in-
formed Gambaiani of all this and advised him that the state’s
offer was a good one. They said it was his own belief that he
could avoid incarceration that caused him to reject the offer.
The state responded to Gambaiani’s rejection of the plea deal
with additional child pornography charges based on newly
discovered evidence. The case then went to trial.
    A jury returned a guilty verdict on all counts, and the trial
court sentenced Gambaiani to 43 years’ imprisonment. But
the Illinois Appellate Court reversed his convictions, conclud-
ing the prosecution had unlawfully withheld potentially ex-
culpatory evidence from the defendant.
    Following that reversal, the state offered Gambaiani a new
plea deal. This time, the state would recommend a 25-year
prison term—far less than the first sentence handed down by
the trial court. At that point, Gambaiani was unwilling to ac-
cept any more than 20 years’ imprisonment. So, he rejected
that offer too, and the case again headed for trial.
    Gambaiani hired a new lawyer, Stephen Brundage, to re-
try his case. At a status conference before the second trial, the
state requested that the courtroom be closed during D.G.’s
4                                                   No. 23-2690

testimony. Illinois law provides that, during the prosecution
of certain sex offenses, a court may impose a limited closure:
       [W]hen the alleged victim of the offense was a
       minor under 18 years of age at the time of the
       offense, the court may exclude from the pro-
       ceedings while the victim is testifying, regard-
       less of the alleged victim’s age at the time of the
       victim’s courtroom testimony, all persons, who,
       in the opinion of the court, do not have a direct
       interest in the case, except the media.
725 ILCS 5/115-11. Brundage did not object to the closure. In-
stead, he asked that Gambaiani’s father be allowed to remain
in the courtroom for the testimony as an interested party. The
court agreed family members should be permitted to stay.
    On the day of D.G.’s testimony, aside from Gambaiani’s
father, only two members of the public were in the courtroom:
a student and a law clerk. The prosecutor volunteered to ask
the pair to leave the room. After confirming no press was pre-
sent, the trial court agreed and had the prosecutor instruct the
court deputies not to allow anyone else in the room during
D.G.’s testimony. But per the court’s earlier ruling, Gam-
baiani’s father remained in the courtroom. At no point did de-
fense counsel object to the closure.
    A jury found Gambaiani guilty on all counts, except for
one charge of predatory criminal sexual assault. He then re-
ceived a new sentence of 34 years’ imprisonment.
    B. Postconviction Procedural History
    Gambaiani appealed his conviction, arguing the trial court
violated his Sixth Amendment right to a public trial by closing
the courtroom during D.G.’s testimony. The Illinois Appellate
No. 23-2690                                                      5

Court rejected his contention. It held that when Gambaiani’s
counsel failed to object to the closure in the trial court, he
waived the argument. People v. Gambaiani (Gambaiani I), No. 2-
14-0124, 

, at *5 (Ill. App. Ct. July 21, 2016).
Even if he had not, the court saw no merit to the Sixth Amend-
ment argument. The closure under 725 ILCS 5/115-11 was
limited in scope, as it applied only during a minor victim’s
testimony and permitted certain people, like Gambaiani’s fa-
ther and members of the press, to remain in place. 

.
Gambaiani sought review from the Supreme Court of Illinois,
but it denied his petition for leave to appeal.
    He then pursued state postconviction relief. Gambaiani
claimed he was denied his right to effective assistance of
counsel. He said that during plea negotiations, his original at-
torneys—again, Halverson and Samuels—failed to alert him
of his full sentencing exposure and, as a result, he mistakenly
rejected the state’s original plea offer. The state trial court con-
ducted an evidentiary hearing on this issue and denied Gam-
baiani relief. It credited his attorneys’ testimony that they in-
formed Gambaiani about his sentencing exposure but that he
rejected the offer because he was determined to avoid prison
time.
    Relying in large part on the trial court’s credibility deter-
minations, the Illinois Appellate Court affirmed. People v.
Gambaiani (Gambaiani II), No. 2-19-0372, 

, at
*6 (Ill. App. Ct. Dec. 22, 2020). The court held that Gambaiani
failed to make the requisite showings to sustain an ineffective
assistance of counsel claim. 

 at *5–6. He appealed that deci-
sion to the Supreme Court of Illinois too, which again denied
review.
6                                                    No. 23-2690

    Gambaiani finally turned to federal court. He petitioned
the district court for a writ of habeas corpus under 

. Gambaiani renewed both his arguments that the state
trial court denied him the right to a public trial and that his
attorneys provided ineffective assistance of counsel. The dis-
trict court refused to grant him relief on both fronts. He now
appeals. We review the denial of a habeas petition de novo.
Powers v. Noble, 

 (7th Cir. 2025).
                      II. Habeas Review
    A state prisoner may petition for a writ of habeas corpus
in federal court “on the ground that he is in custody in viola-
tion of the Constitution or laws or treaties of the United
States.” 

(a). But Congress, in enacting the An-
titerrorism and Effective Death Penalty Act (AEDPA), greatly
circumscribed the power of Article III courts to issue the writ.
Hicks v. Hepp, 

 (7th Cir. 2017). When review-
ing a petition for habeas relief under 

(d), we
afford substantial deference to state convictions. Doing so en-
sures those “convictions are given effect to the extent possible
under law” and simultaneously prevents “federal habeas re-
trials.” Dassey v. Dittmann, 

 (7th Cir. 2017) (en
banc) (internal quotations omitted).
    Section 2254(d) provides petitioners with two well-deline-
ated avenues for obtaining habeas relief. First, the writ may
issue when a state court’s merits-based adjudication of a claim
“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.” 

(d)(1). Within this first avenue, a decision is
deemed “contrary to” clearly established federal law if the
state court reached “a conclusion opposite to that” of the
No. 23-2690                                                    7

Supreme Court on a legal matter, Williams v. Taylor, 

 (2000), or if the state court arrived at an outcome in
direct contradiction to a “materially indistinguishable” case
decided by the Supreme Court. 

    Also within this first avenue, a decision involves an “un-
reasonable application” of federal law when the state court
invokes “the correct governing legal rule” from Supreme
Court precedent but “unreasonably applies it to the facts of
the” case. 

. Importantly, we will fault a state court
only for failing to apply clearly established federal law. In
other words, “relief is available under § 2254(d)(1)’s unrea-
sonable-application clause 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 ques-
tion.” White v. Woodall, 

 (2014) (quoting Har-
rington v. Richter, 

 (2011)).
    Granting habeas relief via § 2254(d)(1) is rare. Indeed, we
have explained that “[i]t is reserved for those relatively un-
common cases in which state courts veer well outside the
channels of reasonable decision-making about federal consti-
tutional claims.” Dassey, 

. In that same vein, the
Supreme Court has repeatedly and forcefully cautioned
courts against readily granting § 2254(d)(1) relief. See, e.g.,
Richter, 

; Virginia v. LeBlanc, 

(2017) (per curiam).
    A second avenue for obtaining habeas relief appears in
§ 2254(d)(2). Under that provision, a federal court may issue
the writ when a state court adjudication “resulted in a deci-
sion that was based on an unreasonable determination of the
facts in light of the evidence presented in the State court pro-
ceeding.” 

(d)(2). Here, too, federal courts are
8                                                    No. 23-2690

cautious to grant relief, reviewing state-court factual findings
with a healthy dose of deference. Dassey, 877 F.3d at 302–03.
“[A] state-court factual determination is not unreasonable
merely because the federal habeas court would have reached
a different conclusion in the first instance.” Wood v. Allen, 

 (2010). The proper inquiry focuses instead on
whether the alleged factual error is beyond debate. “[I]f a re-
view of the record shows only that ‘reasonable minds might
disagree about the finding in question,’” the writ will not is-
sue. Dassey, 

 (internal alterations omitted)
(quoting Brumfield v. Cain, 

, 314 (2015)).
    As in the district court, Gambaiani claims he is entitled to
habeas relief under § 2254(d)(1) and § 2254(d)(2). He submits
that the state is holding him in custody in violation of his Sixth
Amendment rights to a public trial and to effective assistance
of counsel.
                  III. Right to a Public Trial
    The Sixth Amendment guarantees criminal defendants the
right to a public trial. U.S. CONST. amend. VI. That right is en-
forceable against the states via the Fourteenth Amendment. In
re Oliver, 

 (1948).
    Following his second guilty verdict, Gambaiani argued on
appeal that the state trial court denied him his public-trial
right when it cleared members of the public from the court-
room during D.G.’s testimony. Recall, though, the Illinois
Appellate Court concluded that Gambaiani’s attorney acqui-
esced to the courtroom closure, thereby waiving the issue and
precluding appellate review. Gambaiani I, 

, at
*5. In the alternative, the court held that, because the trial
No. 23-2690                                                               9

court only partially closed the courtroom, it did not deny
Gambaiani his Sixth Amendment right. 

.
    A. Waiver
    Gambaiani challenges the Illinois Appellate Court’s con-
clusion that he waived his public-trial right in several ways.
To him, the court’s decision “was based on an unreasonable
determination of the facts.” 

(d)(2). And he ar-
gues the holding was both “contrary to, [and] involved an un-
reasonable application of, clearly established Federal law.” 

§ 2254(d)(1).
   In denying Gambaiani relief, the federal district court con-
cluded that—putting waiver aside—his right to a public trial
was never violated. We nonetheless find it appropriate to re-
view the Illinois Appellate Court’s waiver holding, affording
that court’s decision the proper amount of deference under
AEDPA, as we must. 1
        1. Unreasonable Determination of the Facts
    According to Gambaiani, the Illinois Appellate Court un-
reasonably based its waiver decision on a factual error: that
his counsel “agreed” to closing the courtroom during D.G.’s



    1 In federal district court, it was the state’s position that Gambaiani

procedurally defaulted his public-trial-right claim because the Illinois Ap-
pellate Court’s waiver decision “rest[ed] on independent and adequate
state procedural grounds.” Coleman v. Thompson, 

 (1991);
see also 

 at 729–30 (“The [adequate and independent state grounds] doc-
trine applies to bar federal habeas when a state court declined to address
a prisoner’s federal claims because the prisoner had failed to meet a state
procedural requirement.”). On appeal, the state now concedes Gambaiani
did not procedurally default his claim, so we need not address the issue.
10                                                 No. 23-2690

testimony. He disputes the court’s determination, arguing his
counsel in no way indicated agreement.
    The Illinois Appellate Court’s opinion did note that “de-
fense counsel agreed to the closure.” Gambaiani I, 

, at *5. But it was merely articulating the state’s argu-
ment. In any event, Gambaiani attempts to identify an unrea-
sonable determination of fact by isolating that phrase from its
context. In the next sentence, the Illinois Appellate Court
concluded that Gambaiani’s counsel “acquiesc[ed] to the
courtroom’s closure” when, rather than objecting, he simply
requested the defendant’s father be allowed to remain. 

Read fairly, the state court understood counsel to have
“agreed” to the closure by accepting it without objection—
that is, by acquiescing. And it was counsel’s failure to object,
in the Illinois Appellate Court’s view, that amounted to a
waiver of Gambaiani’s Sixth Amendment argument. See 

    The record firmly supports the state court’s view of the
facts. Before Gambaiani’s second trial, the prosecution raised
the issue of clearing the courtroom during D.G.’s testimony.
Again, Illinois law permits a trial court to exclude “all per-
sons, who, in the opinion of the court, do not have a direct
interest in the case, except the media.” 725 ILCS 5/115-11. De-
fense counsel did not oppose the closure. Instead, he sought a
ruling from the court that Gambaiani’s father was an inter-
ested party and could therefore stay in the courtroom while
D.G. testified. The court agreed. On the day of D.G.’s testi-
mony there were two members of the public in the courtroom,
save Gambaiani’s father—the law clerk and student. The
court confirmed neither was with the press and, consistent
with its earlier ruling, had the pair removed; Gambaiani’s
No. 23-2690                                                  11

father was permitted to stay. Once more, defense counsel
failed to object.
    As explained, habeas relief under § 2254(d)(2) is appropri-
ate when a state court’s factual determination proves unrea-
sonable beyond debate. Rice v. Collins, 

, 341–42
(stating that, even when “[r]easonable minds reviewing the
record might disagree” about a factual determination, the
writ will not issue). Beyond debate here, though, is that the
Illinois Appellate Court correctly construed the record. Gam-
baiani’s counsel acquiesced to the closure, meaning he “ac-
cept[ed]” it “passively.” Acquiesce, BLACK’S LAW DICTIONARY
(11th ed. 2019). Put simply, counsel did not object. Finding no
error in the state court’s factual determination, we therefore
reject Gambaiani’s contention that he is entitled to relief.
       2. Clearly Established Federal Law
    The parties primarily dispute whether the Illinois Appel-
late Court’s conclusion that Gambaiani waived his right to a
public trial by failing to object to the closure alone “was con-
trary to, or involved an unreasonable application of, clearly
established Federal law.” 

(d)(1).
    We can decide with ease that the state court’s holding was
not contrary to clearly established federal law. The Supreme
Court has not squarely addressed whether a defendant
waives his right to a public trial when he fails to object to a
courtroom closure. See United States v. Moon, 

 (11th Cir. 2022) (identifying a split in authority on this
issue). So, the Illinois Appellate Court could not have arrived
at a decision “opposite to that reached by” the Supreme
Court. Williams, 

.
12                                                   No. 23-2690

     Whether the state court’s waiver holding constituted an
unreasonable application of clearly established federal law re-
quires more treatment. Gambaiani posits that the right to a
public trial is a fundamental right—one a defendant cannot
waive based on a failure to object alone. Were this a direct ap-
peal, his argument might have more traction. This court has
held that, “like other fundamental trial rights, a right to a pub-
lic trial may be relinquished only upon a showing that the de-
fendant knowingly and voluntarily waived such a right.”
Walton v. Briley, 

 (7th Cir. 2004). Failure to
object to the closure at trial, without more, will not do. 

    But this is not a direct appeal. Under AEDPA’s deferential
standard of review, we must decide whether the state court’s
decision was “so erroneous that ‘there is no possibility fair-
minded jurists could disagree that’” it runs afoul of Supreme
Court precedent. Nevada v. Jackson, 

, 508–09 (2013)
(per curiam) (quoting Richter, 

). The focus of
this inquiry is necessarily on holdings from the Supreme
Court. Richter, 

. We cannot rely on circuit prec-
edent “to refine or sharpen a general principle” of law. Mar-
shall v. Rodgers, 

 (2013) (per curiam). Nor can we
demand that a state court extend a rationale underpinning Su-
preme Court precedent and apply it to new circumstances.
After all, if a rationale requires extension “before it can apply
to the facts at hand, then by definition the rationale was not
clearly established at the time of the state-court decision.”
White, 

 (internal quotations omitted) (quoting
Yarborough v. Alvarado, 

 (2004)).
    True, the Supreme Court has held that a heightened
waiver standard applies to several criminal-trial rights. See,
e.g., Brady v. United States, 

 (1970) (heightened
No. 23-2690                                                      13

standard applies when waiving one’s right to trial by entering
a guilty plea); Von Moltke v. Gillies, 

, 723–24 (1948)
(heightened standard applies when waiving one’s right to
counsel); Schneckloth v. Bustamonte, 

, 237–38 (1973)
(collecting additional heightened waiver standards). Yet the
Court has not required a heightened showing—something
more than a failure to object—with respect to the public-trial
right. See Peretz v. United States, 

 (1991) (citing
Levine v. United States, 

 (1960)) (noting, albeit
in dicta, that the “failure to object to [the] closing of [a] court-
room is waiver of [the] right to [a] public trial”). That proves
fatal to Gambaiani’s petition. To grant him habeas relief
would be to mandate that the Illinois Appellate Court have
extended a heightened waiver rationale from other Supreme
Court decisions. That we cannot do.
    Nor, as Gambaiani wishes, can we resort to our own cir-
cuit precedent to sharpen a general principle—for example,
that “every reasonable presumption should be indulged
against … waiver”—and apply it to a new context. See Hodges
v. Easton, 

 (1882). Our decision to extend a
heightened waiver standard to the public-trial right in Walton
is thus of no help to Gambaiani under AEDPA’s deferential
review. 

; see also Richter, 

 (ex-
plaining that “even a strong case for relief does not mean the
state court’s” decision applied federal law unreasonably).
    Fairminded jurists could disagree whether a failure to ob-
ject to a courtroom closure constitutes a waiver of one’s right
to a public trial. Richter, 

. In fact, they disagree
on this very question. Although failing to object does not re-
sult in a waiver in our court, the Fifth Circuit has held the op-
posite. United States v. Hitt, 

 (5th Cir. 2006);
14                                                  No. 23-2690

see also Moon, 

 (recognizing a circuit split and
collecting cases). As we have observed in the habeas context,
“[a] division of authority in the lower courts provides some
evidence that [a] matter has not yet been clearly established
by the Supreme Court.” Winston v. Boatwright, 

,
633–34 (7th Cir. 2011).
    All told, Supreme Court precedent leaves open the ques-
tion whether failing to object to a courtroom closure amounts
to a defendant waiving his right to a public trial. The Illinois
Appellate Court thus did not unreasonably apply clearly es-
tablished federal law when it held that Gambaiani waived his
Sixth Amendment right by not objecting to the closure. For
that reason alone, he is not entitled to habeas relief under
§ 2254(d)(1).
     B. Merits
   Although the Illinois Appellate Court’s waiver decision
provides an independent basis for denying Gambaiani relief,
we next address the state court’s alternative holding on the
merits of his Sixth Amendment argument.
    The state court rejected Gambaiani’s contention that the
courtroom closure during D.G.’s testimony resulted in a vio-
lation of his constitutional right to a public trial. It acknowl-
edged that, under relevant Supreme Court precedent, a total
courtroom closure—one “which indiscriminately excludes
the general public” from observing a trial—would run afoul
of the Sixth Amendment. Gambaiani I, 

, at *6
(citing cases). But the Illinois Appellate Court distinguished
cases forbidding total closures from the closure that occurred
at Gambaiani’s trial. The state trial court, relying on Illinois
law, only partially closed the courtroom. Gambaiani’s father
No. 23-2690                                                  15

was present throughout D.G.’s testimony, and the court made
sure no member of the media was asked to leave. To the Illi-
nois Appellate Court, a partial closure—one that “applies
only to the victim’s testimony in sex-offense cases[] and does
not exclude the media and those directly interested in the
case”—raised “none of the evils of a closed trial.” 

    Here again, Gambaiani claims he is entitled to habeas re-
lief under § 2254(d)’s first avenue. He argued in his briefs that
the Illinois Appellate Court’s reasoning was both “contrary to,
[and] involved an unreasonable application of, clearly estab-
lished Federal law.” 

(d)(1).
    At oral argument, though, Gambaiani conceded he cannot
show the state court’s decision contradicts any Supreme
Court precedent. 2 He did so for good reason. Gambaiani has
not identified a Supreme Court case with facts “materially in-
distinguishable” from his own. Williams, 

. And
none exists. See Zornes v. Bolin, 

 (8th Cir.
2022) (observing “[t]he Supreme Court has never addressed”
a case involving the “‘partial closure’ of … any phase of a
trial[]”). His only route to relief, then, requires him to show
the Illinois Appellate Court’s reasoning amounted to an un-
reasonable application of clearly established federal law.
   To make that showing, Gambaiani relies primarily on two
Supreme Court decisions: Waller v. Georgia, 

 (1984),
and Presley v. Georgia, 

 (2010) (per curiam).
    At issue in Waller was whether “a hearing on a motion to
suppress evidence may be closed to the public over the objec-
tion of the defendant.” 467 U.S. at 40–41. The Court held first


   2 Oral Arg. at 6:20–7:35, 7:55–8:08.
16                                                   No. 23-2690

that the Sixth Amendment right to a public trial extends to
suppression hearings. Id. at 43. It then articulated a standard
for deciding when a total courtroom closure—one that ex-
cludes “all persons other than witnesses, court personnel, the
parties, and the lawyers”—is appropriate. Id. at 48, 42. To jus-
tify a closure,
        the party seeking to close the hearing must ad-
        vance an overriding interest that is likely to be
        prejudiced, the closure must be no broader than
        necessary to protect that interest, the trial court
        must consider reasonable alternatives to closing
        the proceeding, and it must make findings ade-
        quate to support the closure.
Id. at 48.
   Later, in Presley, the Court was tasked with resolving
whether excluding the public from a jury voir dire—again,
over a defendant’s objection—amounted to a Sixth Amend-
ment violation. 558 U.S. at 209–10. It concluded the right to a
public trial extends to voir dire and held that a trial court must
consider the Waller factors before closing a courtroom under
those circumstances, too. Id. at 213–14.
    Gambaiani faults the state trial court for clearing members
of the public from the courtroom without first considering the
factors set out in Waller and reaffirmed in Presley. And he
claims the Illinois Appellate Court misapplied clearly estab-
lished federal law when it sanctioned such a result.
   No doubt a trial court must consider the Waller factors be-
fore fully closing a courtroom over a defendant’s objection for
even a portion of a criminal trial. See, e.g., id. But the Supreme
Court has not held that a partial courtroom closure triggers
No. 23-2690                                                    17

those factors. See Zornes, 

. Both Waller and Pres-
ley dealt with total closures. Not so here. Gambaiani’s father
was present during D.G.’s testimony, and the trial court
checked to make sure no member of the press was removed.
    We cannot say the Illinois Appellate Court unreasonably
applied clearly established federal law by not invoking the
Waller factors. Holding otherwise would amount to demand-
ing that the state court have extended the rationale underpin-
ning Waller and Presley to a new context: a partial courtroom
closure. A habeas court can make no such demand. White, 

. “AEDPA’s carefully constructed framework
‘would be undermined,’” after all, “if habeas courts intro-
duced rules not clearly established under the guise of exten-
sions of existing law.” 

 (quoting Yarborough, 

).
    If that were not enough, no Supreme Court decision has
mandated that a trial court evaluate the Waller factors absent
defense counsel raising an objection to the courtroom closure.

 (counsel objected to closure during suppression
hearing); Presley, 

 (counsel objected to closure
during voir dire). We would thus break new ground if we
held that a trial court had to raise the factors sua sponte. The
Supreme Court has repeatedly cautioned that habeas review
is not the proper time for a federal court to establish new fed-
eral rules. See, e.g., Knowles v. Mirzayance, 

(2009).
     Because clearly established federal law did not mandate
an evaluation of the Waller factors, we find no fault in how the
Illinois Appellate Court resolved the merits of Gambaiani’s
Sixth Amendment claim. By way of recap, the court reasoned
that a closure under 725 ILCS 5/115-11 comports with the
Sixth Amendment because it is “limited in scope.” Gambaiani
18                                                           No. 23-2690

I, 

, at *6. The statute seeks to protect a minor
victim testifying in a sex-offense case. See 

 And it expressly
contemplates allowing interested parties and the press to re-
main in the courtroom. 

    Fairminded jurists could agree with the Illinois Appellate
Court’s reasoning. Indeed, federal “courts of appeals have
concluded that partial closures may be justified by a ‘substan-
tial reason’ without the ‘overriding interest’ that Waller re-
quires to justify a complete closure.” Zornes, 

(quoting United States v. Thompson, 

 (8th Cir.
2013)); see also Judd v. Haley, 

 (11th Cir.
2001) (same). The Supreme Court itself has recognized that
“the protection of minor victims of sex crimes from further
trauma and embarrassment” constitutes a “compelling” inter-
est that might counsel in favor of a courtroom closure. See
Globe Newspaper Co. v. Superior Ct., 

 (1982). Far
from unreasonable, then, the state court’s decision finds a firm
footing in federal law.
    Two of Gambaiani’s counterarguments merit discussion.
First, citing Globe Newspaper, he resists the Illinois Appellate
Court’s description of the closure as a partial one. 3 In that
case, the Supreme Court took issue—on First Amendment
grounds—with a Massachusetts statute, which required


     3 Globe Newspaper is a First Amendment, rather than Sixth Amend-

ment, case. But the First Amendment implicitly protects the right of “the
press and general public” to “access … criminal trials.” 

. The Su-
preme Court has recognized “that the explicit Sixth Amendment right of
the accused is no less protective of a public trial than the implicit First
Amendment right of the press and public.” Waller, 

. So, as
the district court correctly noted, both constitutional rights may inform
our analysis.
No. 23-2690                                                     19

courts to “exclude the general public from the court room, ad-
mitting only such persons as may have a direct interest in the
case” while a minor victim of a sexual offense testified. Globe
Newspaper, 

 n.1 (internal quotation and citation
omitted). Gambaiani says Globe Newspaper stands for the
proposition that a courtroom closure is total when only peo-
ple who have an interest in the case are permitted to stay. So,
for Gambaiani, the courtroom closure here was total because
only his father, who had a direct interest in the case, remained
for D.G.’s testimony.
    Gambaiani overreads Globe Newspaper. The Court did not,
as he contends, hold that a courtroom closure is total when
the press and other members of the public are removed but
an interested party is permitted to stay. Rather, the Court’s
express holding was that a “mandatory closure rule,” like
Massachusetts’s, “violates the First Amendment.” 

.
No such rule is at issue in this case. Quite unlike the trial court
in Globe Newspaper, which removed members of the media
over their objections, the state trial court here sought to ensure
anyone with the press could stay in the courtroom. Gambaiani
I, 

, at *6. That remains true even though no-
body from the media actually attended Gambaiani’s trial.
    Gambaiani’s father was present during D.G.’s testimony,
rendering the courtroom closure a partial one as a matter of
fact. Neither the Court’s decision in Globe Newspaper nor the
apparent lack of media interest in Gambaiani’s criminal trial
alters that truth.
    As for Gambaiani’s second counterargument, he says the
courtroom closure was effectively total because the state trial
court instructed personnel not to let anyone in after the doors
closed—which could have barred late-arriving media and
20                                                   No. 23-2690

interested parties. This argument, like the last, ignores that
the court allowed Gambaiani’s father to remain in the room
during D.G.’s testimony.
    And even if the courtroom closure was handled in a less-
than-ideal way, the Illinois Appellate Court still did not mis-
apply clearly established federal law beyond debate. See, e.g.,
Brown v. Payton, 

 (2005). Reasonable
minds could certainly agree that the trial court incorrectly in-
structed deputies to block all additional entrants. But doing
so did not amount to a violation of Gambaiani’s Sixth Amend-
ment right to a public trial. Gambaiani I, 

, at
*6. Indeed, this court has held that a limited closure of a court-
house to late arrivals before the conclusion of a defendant’s
trial did not amount to a violation of his public-trial right
when the courtroom remained accessible to those already pre-
sent. See United States v. Anderson, 

 (7th Cir.
2018); see also Lacaze v. United States, 

, 519–21 (5th
Cir. 1968) (no Sixth Amendment violation when courtroom
door was temporarily locked but “[t]here may well have been
spectators in the courtroom at the time”). Relief under
§ 2254(d)(1) therefore remains unavailable to Gambaiani. See
Richter, 

.
                      *         *         *
    The state court’s holding that Gambaiani waived his
public-trial right was not contrary to, or an unreasonable ap-
plication of, federal law. Nor was it based on an unreasonable
determination of the facts. For those reasons alone, he is not
entitled to habeas relief. Waiver aside, he remains ineligible
for relief, as the Illinois Appellate Court’s decision on the mer-
its of the Sixth Amendment issue was likewise not an
No. 23-2690                                                   21

unreasonable application of clearly established federal law
under AEDPA’s deferential standard.
        IV. Right to Effective Assistance of Counsel
   We arrive last at Gambaiani’s argument that he was de-
nied his Sixth Amendment right to effective assistance of
counsel—a right that extends to plea bargaining. Missouri v.
Frye, 

 (2012) (“The right to counsel is the
right to effective assistance of counsel.”). To establish a Sixth
Amendment violation, the defendant must make two show-
ings under Strickland v. Washington, 

 (1984). “First,
the defendant must show that counsel’s performance was de-
ficient.” 

. Then he “must show that the deficient per-
formance prejudiced” him. 

    Seeking postconviction relief in the state system,
Gambaiani alleged that his original attorneys, Halverson and
Samuels, performed deficiently because they did not explain
the extent of his sentencing exposure—including that his
predatory sexual assault counts would result in mandatory
consecutive sentences under Illinois law. According to Gam-
baiani, Halverson and Samuels gave him the false hope that
he could avoid prison time altogether. He accordingly re-
jected an otherwise favorable offer from the state to enter a
guilty plea with a sentencing exposure of just 4 to 15 years. To
Gambaiani, his attorneys’ deficient performance prejudiced
him, as he ultimately received a much higher sentence of 34
years’ imprisonment.
   After an evidentiary hearing on the matter, the state trial
court denied Gambaiani’s petition for postconviction relief.
Halverson and Samuels both testified at the hearing, confirm-
ing they informed Gambaiani about the extent of his potential
22                                                    No. 23-2690

sentence. But they explained he was bent on rejecting any deal
that involved incarceration. The state trial court credited their
testimony and discredited Gambaiani’s testimony to the con-
trary. It found as a matter of fact that the attorneys informed
Gambaiani about his sentencing exposure but that he none-
theless rejected the state’s offer based on his unwillingness to
serve prison time.
    The Illinois Appellate Court affirmed. Relying in large
part on the trial court’s credibility determinations, it held that
Gambaiani could not show his lawyers performed deficiently.
Gambaiani II, 

, at *5. The state trial court’s
credibility determinations also influenced the Illinois Appel-
late Court’s prejudice analysis. Halverson and Samuels of-
fered testimony that Gambaiani “was adamant that he should
receive probation and not a penitentiary sentence.” 

.
So, the court reasoned he “could not have been prejudiced by
his attorneys’ advice as his decision was not based on their
advice.” 

 It was instead based on his own false belief that
he could avoid prison despite his criminal conduct. 

   Here again, Gambaiani’s petition for a writ of habeas cor-
pus cites the § 2254(d)(2) avenue for obtaining relief. He sub-
mits that the Illinois Appellate Court’s decision rejecting his
ineffective assistance of counsel claim was based on an unrea-
sonable determination of the facts. 

(d)(2). We
must disagree once more.
    It bears repeating: A habeas court will not readily part
ways with a state court’s factual findings. Dassey, 877 F.3d at
302–03. We give great deference to credibility determinations
in particular. Sanders v. Radtke, 

 (7th Cir. 2022)
(“Such credibility determinations are notoriously difficult to
overturn under § 2254(d)(2).” (internal quotation omitted)).
No. 23-2690                                                  23

And although a petitioner “may disagree with the state
court’s weighing of certain facts, the highly deferential habeas
review does not permit a federal court to conduct its own in-
dependent inquiry and reweigh factors as a de novo matter.”
Id. at 510–11 (internal quotation omitted).
    Credibility determinations drove the Illinois Appellate
Court’s Strickland analysis here and, consequently, its deci-
sion to deny Gambaiani postconviction relief. We see no error
in its findings that would justify issuing a habeas writ.
    On Strickland’s performance prong, the record supports
that Gambaiani’s lawyers adequately informed him of his
sentencing exposure. Halverson testified that, before the state
ever made a plea offer, he talked with Gambaiani about pos-
sible sentences. And he testified it was his normal practice to
go over whether multiple sentences had to be served consec-
utively. Samuels recounted listening to Halverson describe
sentencing outcomes to Gambaiani on the day the state made
its plea offer, including the fact that sexual assault sentences
would run consecutively.
    On Strickland’s prejudice prong, the record also shows that
Gambaiani was unwilling to accept a deal that involved
prison time, regardless of what his lawyers told him. Both of
his attorneys indicated under oath that he was adamant about
that. And his aversion to being incarcerated is all but con-
firmed by the fact that, even after initially receiving a 43-year
sentence, Gambaiani rejected a separate 25-year plea deal
leading up to his second trial.
    The Illinois courts credited all this testimony, and nothing
in the record counsels overturning those rulings here. See id.
at 511.
24                                                   No. 23-2690

    Gambaiani pushes back, dedicating pages of his briefs to
the “avalanche of evidence showing that his attorneys’ testi-
mony at the postconviction hearing was incredible.” The dis-
trict court did an admirable job rejecting many of the factual
inconsistencies that Gambaiani purports to have identified.
Yet that work need not be repeated here because a habeas
court’s task is not to review the record de novo. Id. at 510–11.
Instead, AEDPA’s deferential standard requires that federal
courts give significant leeway to state courts on factual issues
like this one. Removed as we are from the original postcon-
viction proceedings, we cannot conclude that the Illinois
courts erred in crediting the testimony of attorneys Halverson
and Samuels.
    The district court was right to reject Gambaiani’s petition
for a writ of habeas corpus on this front, too.
                         V. Conclusion
     Gambaiani raises a variety of arguments for why he is en-
titled to a writ of habeas corpus. But he has no route to relief
given AEDPA’s deferential standard of review. We therefore
AFFIRM the district court’s decision to deny the petition in full.