United States v. Tsarnaev

Background

A man who planted bombs at the Boston Marathon, killed and injured many people, was tried, convicted, and sentenced to death for multiple federal crimes. The trial judge used a long juror questionnaire but refused one proposed question that would have required each potential juror to list facts they learned from the media. At sentencing the defendant sought to introduce statements tying his older brother to an earlier triple murder in Waltham to show the brother was the mastermind. The trial judge excluded that Waltham evidence. The First Circuit vacated the death sentences on both grounds.

Reasoning

The Supreme Court asked whether the trial judge abused her discretion by (1) refusing to ask every juror what media facts they had learned and (2) excluding the Waltham evidence at sentencing. The Court said no. It explained that decisions about what questions to ask prospective jurors lie mainly with the trial judge and that an appeals court cannot use supervisory power to impose a blanket question. On the Waltham evidence, the Court applied the Federal Death Penalty Act’s balancing test and found the judge reasonably excluded unreliable, confusing evidence whose probative value was low. The Court therefore reversed the appeals court and reinstated the death sentences.

Real world impact

The decision confirms that trial judges have broad authority to shape voir dire in high-profile cases and to bar weak or confusing third-party accusations during death-penalty sentencing. Defendants face limits when trying to force detailed media-content questioning of all jurors. The ruling will guide lower courts handling publicity, juror questioning, and mitigation evidence in capital trials.

Dissents or concurrances

A dissent argued the Waltham evidence should have been admitted as important mitigation and urged careful review in death cases. A concurrence questioned whether courts of appeals possess broad supervisory power.