United States v. Tsarnaev

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Supreme Court of the United States
United States v. Tsarnaev
Term: 2021
Important Dates
Argued: October 13, 2021
Decided: March 4, 2022
Outcome
Reversed
Vote
6-3
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Amy Coney Barrett • Neil Gorsuch
Dissenting
Stephen Breyer • Sonia Sotomayor • Elena Kagan

United States v. Tsarnaev is a case that was decided by the Supreme Court of the United States on March 4, 2022, during the court's October 2021-2022 term. The case was argued before the court on October 13, 2021. The court reversed the decision of the U.S. Court of Appeals for the 1st Circuit in a 6-3 ruling, holding the 1st Circuit improperly vacated Tsarnaev's death penalty convictions.[1]

Justice Clarence Thomas delivered the majority opinion of the court. Justice Amy Coney Barrett filed a concurring opinion, in which Justice Neil Gorsuch joined. Justice Stephen Breyer filed a dissenting opinion, in which Justices Sonia Sotomayor and Elena Kagan joined except as to Part II-C.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2013, Dzhokhar and Tamerlan Tsarnaev detonated two homemade bombs at the Boston Marathon. In 2015, Dzhokhar was indicted on and convicted of 30 criminal charges related to the bombings. For several offenses, he was sentenced to death. Dzhokhar appealed to the U.S. Court of Appeals for the 1st Circuit, alleging that the jury- and venue-selection processes in his case violated his constitutional rights to due process, an impartial jury, and a reliable sentencing ruling; and that the federal district court judge erred in applying the death penalty for some of the convictions. The 1st Circuit affirmed in part, reversed in part, and vacated in part the U.S. District Court for the District of Massachusetts' ruling and remanded the case for further proceedings. Click here to learn more about the case's background.
  • The issue: The case concerned the death penalty convictions of Dzhokhar Tsarnaev, who was convicted of 30 criminal offenses related to the 2013 Boston Marathon bombings.[2][3]
  • The questions presented:
    "1. Whether the court of appeals erred in concluding that respondent’s capital sentences must be vacated on the ground that the district court, during its 21-day voir dire, did not ask each prospective juror for a specific accounting of the pretrial media coverage that he or she had read, heard, or seen about respondent’s case.
    "2. Whether the district court committed reversible error at the penalty phase of respondent's trial by excluding evidence that respondent's older brother was allegedly involved in different crimes two years before the offenses for which respondent was convicted."[4][5]
  • The outcome: The court reversed the decision of the U.S. Court of Appeals for the 1st Circuit in a 6-3 ruling.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 1st Circuit. To review the lower court's opinion, click here.[3]


    Table of contents

    • Timeline: The timeline details key events in the case.
    • Background: This section details how the case originated, the questions of law at issue, and legal proceedings prior to the U.S. Supreme Court granting review.
    • Questions presented: This section includes the questions presented to the Supreme Court for appellate review.
    • Oral argument: This section provides information on oral argument in the case.
    • Outcome: This section provides details on the outcome of the case once SCOTUS issues an opinion.
    • October term 2021-2022: This section provides information on the SCOTUS term when the cases were argued and decided.


    Timeline

    The following timeline details key events in this case:

    • March 4, 2022: The U.S. Supreme Court reversed the decision of the U.S. Court of Appeals for the 1st Circuit in a 6-3 ruling.
    • October 13, 2021: The court heard oral argument.
    • March 22, 2021: The court agreed to hear the case.
    • October 6, 2020: The acting Solicitor General of the United States Jeffrey Wall appealed to the U.S. Supreme Court.
    • July 31, 2020: The 1st Circuit affirmed in part, reversed in part, and vacated in part the ruling of the United States District Court for the District of Massachusetts and remanded the case for further proceedings.

    Background

    On April 15, 2013, Dzhokhar Tsarnaev and his older brother Tamerlan detonated two homemade bombs at the Boston Marathon. Three people died and more than 250 people were injured. Tamerlan died on April 18, 2013, in a confrontation with police officers.[3] In 2015, Dzhokhar Tsarnaev was indicted on 30 criminal charges related to the bombing. At trial in the U.S. District Court for the District of Massachusetts, Tsarnaev said that he did commit the offenses but alleged that Tamerlan had intimidated him into committing the acts. Tsarnaev was found guilty on all charges against him. The jury recommended the death sentence on several of the eligible criminal counts and the judge imposed those sentences, along with other sentences related to the remaining charges.[2][3]

    Tsarnaev appealed the case to the United States Court of Appeals for the 1st Circuit, asking the court to review several jury- and venue-selection claims for legal error. Tsarnaev asserted that his constitutional right to an impartial jury was violated because of the venue of his jury trial. He argued that the community's exposure to the bombings and the related publicity prior to the trial created a potential for bias for the jurors and that the jurors' voir dire responses demonstrated bias against Tsarnaev. The government argued that the pre-trial media coverage had not created prejudice among the potential and selected jurors. Tsarnaev also asserted that the judge erred during the jury selection process, citing legal precedents set in the cases Morgan v. Illinois (1992) and Patriarca v. United States (1969). Tsarnaev concluded that the trial's proceedings violated his rights to due process, an impartial trial, and a reliable sentencing ruling. The government contended that the jury was not biased.[3]

    On July 31, 2020, the 1st Circuit concluded that the district court judge erred by denying Tsarnaev's request to ask potential jurors content-specific questions about the publicity surrounding the case before the trial. The 1st Circuit ruled that this did not meet the legal standard it established in Patriarca. The court also held that the district court judge erred by not acquitting Tsarnaev of three convictions of carrying a firearm during crimes of violence. The district court held that each of the underlying offenses constituted a crime of violence, whereas the 1st Circuit reached the opposite interpretation of the law. The 1st Circuit vacated Tsarnaev's death sentences and reversed the three firearm convictions at issue. The court remanded the case for judgments of acquittal on the three firearm convictions and for the district court to conduct a new jury trial limited to sentencing for the death-eligible counts. The 1st Circuit affirmed the remaining convictions and the related sentences of life imprisonment that Tsarnaev did not challenge.[3]

    Questions presented

    The petitioner presented the following questions to the court:[4][5]

    Questions presented:
    “ 1. Whether the court of appeals erred in concluding that respondent’s capital sentences must be vacated on the ground that the district court, during its 21-day voir dire, did not ask each prospective juror for a specific accounting of the pretrial media coverage that he or she had read, heard, or seen about respondent’s case.
    2. Whether the district court committed reversible error at the penalty phase of respondent's trial by excluding evidence that respondent's older brother was allegedly involved in different crimes two years before the offenses for which respondent was convicted.[6]     		”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 6-3 opinion, the court reversed the decision of the U.S. Court of Appeals for the 1st Circuit, holding the 1st Circuit was wrong to vacate Tsarnaev's death sentence. Writing for the majority, Justice Thomas concluded that the District Court of Massachusetts did not abuse its discretion by refusing to allow questions about pretrial media coverage.[1]

    Justice Thomas delivered the opinion of the court, joined by Chief Justice Roberts and Justices Alito, Gorsuch, Kavanaugh, and Barrett. Barrett filed a concurring opinion, in which Gorsuch joined. Justice Breyer filed a dissenting opinion, in which Justices Sotomayor and Kagan joined except as to Part II-C.[1]

    Opinion

    In the court's majority opinion, Justice Thomas wrote:[1]

    “

    [The District Court's] jury selection process was both eminently reasonable and wholly consistent with this Court's precedents. The Court of Appeals erred in holding otherwise. ... This Court has held many times that a district court enjoys broad discretion to manage jury selection, including what questions to ask prospective jurors. See, e.g., Skilling, 561 U.S., at 387, n. 20; Mu'Min, 500 U.S., at 427; Ristaino, 424 U.S. at 594; Ham, 409 U.S., at 527; Connors, 158 U.S., at 413. As the Court of Appeals acknowledged, our cases establish that a reviewing court may set aside a district court's questioning only for an abuse of direction. See 968 F. 3d, at 56. The Court of Appeals declined to apply that settled standard of review. ... Dzhokhar Tsarnaev committed heinous crimes. The Sixth Amendment nonetheless guaranteed him a fair trial before an impartial jury. He received one. [6]

    		”
    —Justice Thomas

    Concurring opinion

    Justice Barrett filed a concurring opinion, joined by Justice Gorsuch. In her concurring opinion, Justice Barrett wrote:[1]

    “

    In this case, the First Circuit asserted “supervisory power” to impose a procedural rule on the District Court. Because that rule (which required a district court to ask media-content questions on request in high-profile prosecutions) conflicts with our cases (which hold that a district court has broad discretion to manage jury selection), I agree with the Court that the First Circuit erred.

    I write separately to note my skepticism that the courts of appeals possess such supervisory power in the first place. ... [Here], the First Circuit did not adopt a rule regulating its own proceedings—it adopted a blanket rule that all district courts in its jurisdiction must follow on pain of reversal. ... This case does not require us to resolve whether the courts of appeals have supervisory authority over district courts. Either way, the First Circuit erred. At some point in the future, however, it would be worth revisiting our dicta. [6]

    		”
    —Justice Barrett

    Dissenting opinion

    Justice Breyer filed a dissenting opinion, joined by Justices Sotomayor and Kagan.

    In his dissent, Justice Breyer wrote:[1]

    “

    In my view, the Court of Appeals acted lawfully in holding that the District Court should have allowed Dzhokhar to introduce this evidence. ... I believe that the Court of Appeals was correct that the District Court abused its discretion by excluding the Waltham evidence. The record does not adequately support exclusion for the District Court’s stated reasons. ... For that reason, the District Court should conduct a new sentencing proceeding. I need not, and do not, reach the pretrial publicity question. I note, however, that when considering that issue, the Court refers to the power of the federal appeals courts to promulgate supervisory rules. [6]

    		”
    —Justice Breyer

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, United States v. Tsarnaev, decided March 4, 2022
    2. ↑ 2.0 2.1 United States District Court for the District of Massachusetts, "United States v. Dzhokhar Tsarnaev: JUDGMENT IN A CRIMINAL CASE," June 24, 2015
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 United States Court of Appeals for the 1st Circuit, United States v. Tsarnaev, decided July 31, 2020
    4. ↑ 4.0 4.1 Supreme Court of the United States, "20-443 UNITED STATES V. TSARNAEV: Questions presented," accessed March 22, 2021
    5. ↑ 5.0 5.1 Supreme Court of the United States, "Petition for a writ of certiorari," accessed March 22, 2021
    6. ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 13, 2021
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," accessed October 13, 2021
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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