RIO DE JANEIRO — A nation divided. A populist leader casting doubts on the electoral process and refusing to accept defeat. A violent uprising by his followers in the capital to uphold his authority.
This narrative mirrors not only that of Donald Trump but also parallels the story of Brazil’s Jair Bolsonaro. The two largest democracies in the Western Hemisphere have encountered comparable challenges in the years 2020 and 2022, respectively, yet their institutional reactions have been vastly different.
In Brazil, authorities quickly deemed Bolsonaro ineligible for office until 2030, a sanctions that may extend due to ongoing criminal investigations. Conversely, Republicans in the U.S. Senate assisted in acquitting Trump during an impeachment trial that could have barred him from future presidential runs. The U.S. legal system moved at a sluggish pace as it faced the unprecedented situation of prosecuting a former president.
The contrasting responses to Jair Bolsonaro and Donald Trump provide a compelling study on how democracies endeavor — and at times struggle — to hold their foremost leaders accountable. As rising unease over the stability of democratic governments grips the world, these cases are being observed closely.
Brazilian democracy is relatively young, having transitioned from military dictatorship only four decades ago. The specter of authoritarianism still profoundly affects many Brazilians, motivating them to engage with narratives that reflect their history, such as the recent film “I’m Still Here.” Despite being an ardent proponent of the former regime, Bolsonaro triumphed in his first presidential bid.
In contrast, during the tumult of 2020, the United States had little experience with authoritarian rule, leading to a level of naïveté among its institutions, as noted by Steven Levitsky, a prominent scholar on democracy. “Many influential figures, particularly among conservative factions on the Supreme Court, underestimated Trump as a threat, failing to respond appropriately,” Levitsky commented, indicating that some U.S. elites cannot fathom a collapse of democracy.
Levitsky also highlighted deficiencies in the U.S. Constitution regarding the prohibition of parties and candidates considered dangerous, a power that Brazil’s Constitution provides. Following its military past, Brazil designed its Constitution with provisions to prevent future coups, creating mechanisms that allow electoral authorities to disqualify candidates whose actions threaten electoral integrity. This differs significantly from the U.S., where each state decides the eligibility of candidates independently.
Six months after Bolsonaro’s term ended, the court ruled him ineligible for future elections until 2030 due to his abuse of power and the propagation of unfounded claims about the electronic voting system. Justice Edson Fachin remarked on the robustness of Brazil’s democratic institutions, attributing their strength to the commitment of the populace who shaped the Constitutional framework.
Notably, the electoral court exhibited patience, only taking action after Bolsonaro’s narrow defeat to Luiz Inácio Lula da Silva, acting neither dramatically nor in a manner that could make Bolsonaro a martyr but isolating him sufficiently to diminish his political influence, as pointed out by anthropologist Isabela Kalil.
In the political landscape, while the U.S. is predominantly a two-party system under Trump’s control, Brazil has a fragmented party system with multiple factions and fluctuating alliances. This structure lessens the incentive for right-wing politicians to align blindly with Bolsonaro. Following the election results, prominent political figures promptly endorsed the outcome—an act that contrasts sharply with the hesitation exhibited by Republican leaders in the U.S.
Bolsonaro continues to assert his ambitions for the presidency in 2026, showing he still holds substantial electoral allure. His allies are looking to prop him up with the assistance of Trump, whom Bolsonaro has openly admired. “With Trump, I am confident that new winds are blowing,” declared federal lawmaker Bia Kicis, a committed supporter of Bolsonaro.
While U.S. authorities named a special counsel to investigate Trump’s actions post-election in late 2022, Brazilian investigators rapidly scrutinized Bolsonaro’s involvement in the January 8 uprising, alongside allegations of embezzlement of gifts from Saudi Arabia and falsification of vaccination records. All three inquiries have resulted in formal charges, and the Prosecutor General is contemplating further charges against Bolsonaro.
If the legal actions proceed, Bolsonaro may face trial next year, which could deepen his ineligibility and potentially result in imprisonment. He has consistently denied any wrongdoing and labeled the judicial action as persecution. Over the years, Bolsonaro has escalated his rhetoric against the court, particularly targeting Justice Alexandre de Moraes, which has plunged Brazil into a near institutional crisis.
Critics from far-right circles have expressed discontent over these investigations, and some moderate analysts have raised concerns about fairness. “Disqualifying a popular leader could also undermine democracy,” cautioned Winter, reflecting sentiments among some Brazilian jurists who are wary of the investigations’ integrity.
Both the United States and Brazil have seen accountability efforts targeting those directly involved in respective uprisings. In the U.S., over 1,500 participants in the January 6 Capitol riots faced federal charges. Similarly, Brazil has processed legal complaints against 898 people associated with the January 8 insurrection, resulting in 371 convictions, while others entered leniency agreements. President Lula remarked that accountability measures would be upheld.
