United States v. Tsarnaev

On April 15, 2013, Dzhokhar Tsarnaev and his brother Tamerlan detonated two pressure-cooker bombs near the Boston Marathon finish line, killing three spectators and injuring hundreds. During the ensuing manhunt, they shot and killed an MIT police officer. Tsarnaev was convicted on 30 federal counts in 2015 and sentenced to death. In 2020, the First Circuit Court of Appeals vacated the death sentence, ruling that the trial court improperly excluded mitigating evidence about Tamerlan’s involvement in an earlier triple homicide and failed to adequately question jurors about pretrial media exposure. The Supreme Court granted certiorari and, on March 4, 2022, issued a 6-3 decision reversing the First Circuit. The majority held that the district court did not abuse its discretion under the Federal Death Penalty Act, that the excluded evidence was not so significant as to require a new sentencing hearing, and that the jury selection process was fair. The death sentence was reinstated.

The Supreme Court reversed the judgment of the Court of Appeals, reinstating Dzhokhar Tsarnaev’s capital sentence.

Whether the court of appeals erred in vacating the death sentence by concluding that the district court abused its discretion in excluding mitigating evidence of the brother’s possible participation in a triple homicide, and in finding that the district court’s jury voir dire regarding pretrial publicity was constitutionally inadequate.

The ruling reinforced the wide discretion granted to federal district judges in conducting death penalty sentencing proceedings and confirmed a high bar for appellate reversal of jury sentencing verdicts. It underscored the judiciary’s commitment to finality in terrorism-related capital cases and was viewed as delivering long-awaited closure for the victims’ families and the Boston community, while reigniting broader national debate over the federal death penalty.