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United Statesv.Tsarnaev

CourtSupreme Court of the United States
Docket No.20-443
DecidedMarch 4, 2022
Reporter595 U.S. 302
JudgesSupreme Court of the United States
Tags
CriminalCriminal ProcedureEvidenceSentencingDeath PenaltyJury SelectionOther-Acts EvidenceMurder & MayhemTales From the CryptReversal
Case Summary

Dzhokhar Tsarnaev was convicted of crimes arising from the Boston Marathon bombing and related violence, and a jury imposed six capital sentences. The First Circuit vacated those sentences, finding error in the district court’s refusal to ask prospective jurors to identify the facts they had learned from media coverage and in its exclusion of evidence that Tsarnaev’s brother may have participated in earlier Waltham murders. The Supreme Court reversed. It held that the district court acted within its broad discretion during jury selection, because the court used an extensive written questionnaire, individualized voir dire, and instructions directing jurors to decide the case on trial evidence rather than publicity. The Court also held that the court properly excluded the Waltham evidence under the Federal Death Penalty Act: the evidence had limited probative value regarding the brother’s alleged influence, while risking unfair prejudice and a confusing mini-trial when the alleged witnesses were unavailable. The Court declined to decide broader questions about the First Circuit’s supervisory authority and reversed the appellate judgment. Justice Barrett concurred, and Justice Breyer dissented, joined in substantial part by Justices Sotomayor and Kagan.

Opinion

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