United States v. Tsarnaev

Applying the discretionary standard to a capital case with extraordinary pretrial publicity surrounding the Boston Marathon bombing, the trial judge's limitation on voir dire questions about media exposure was reasonable because the procedure still adequately tested for bias through jurors' responses about their ability to presume innocence and decide the case on evidence alone. Similarly, the exclusion of evidence that Tsarnaev's brother had committed an unrelated triple murder fell within the judge's discretion because the prior crimes' probative value to the sentencing determination was substantially outweighed by the risk of confusion and jury prejudice from introducing collateral crimes unrelated to Tsarnaev's own culpability. Even if the rulings were debatable, any error in either category was harmless given the overwhelming evidence of Tsarnaev's guilt and the nature of his aggravating conduct--planting explosives that killed and maimed dozens at a public event.