Citing the perils of juror dishonesty, the U.S. Court of Appeals for the First Circuit has vacated the first federal death sentence handed down in Massachusetts and ordered a new penalty proceeding.

Lawyers for defendant Gary Lee Sampson, sentenced to death in 2003 for killing two people during a violent crime spree, convinced a three-judge panel to take the rare step of vacating a jury's decision. The U.S. Justice Department had urged the court to reinstate the death sentence.