Earlier this month, Brazil did something the United States couldn’t: it punished a president who tried to overturn an election. Jair Bolsonaro lost in 2022, claimed fraud, encouraged his supporters to storm Brasília, and is now serving a 27-year sentence for subverting democracy. Donald Trump lost in 2020, made nearly identical false claims, watched as his most fervent supporters sacked the U.S. Capitol—and he’s back in the White House. That contrast is telling. It goes to the heart of whether democracies can enforce the rules that make them democracies in the first place. Brazil’s message is clear: accountability is possible, even in a deeply polarized society. The United States’ is equally stark: polarization can become an alibi for impunity.
The similarities between the two cases are striking. In both countries, a right-wing populist president spent years sowing doubt about the press, the courts, and electoral authorities. Each insisted —against all evidence—that he had won an election he narrowly lost. Each inspired a mob to storm the capital and intimidate members of the other branches of government. Both drew from the same playbook of denial, grievance, and conspiracy.
The difference lies in what came next. In Brazil, the electoral court acted quickly, barring Bolsonaro from office until 2030. Prosecutors indicted him within two years, and the case went straight to the Supreme Federal Court, which sentenced him to nearly three decades behind bars. Political and business elites, even former allies, largely stood aside and let the process run its course. In the United States, institutions stalled. Several Republicans broke with Trump after the January 6 insurrection, but their party ultimately blocked his second impeachment, which would have barred him from future office. During the Biden administration, Attorney General Merrick Garland’s Justice Department waited almost three years to bring federal charges—by then, Trump was already running for president again and could cast himself as the target of persecution. The Supreme Court stepped in to shield much of his conduct as “official acts.” Delay became Trump’s best ally, allowing him to transform accountability into grievance and grievance into power.
The irony, as Omar G. Encarnación argues, is that Brazil’s institutional resilience took shape just as the United States was pouring resources into democracy promotion across the western hemisphere. Amid the regional wave of democratization in the 1980s, Washington funneled millions into strengthening courts, electoral oversight, and civil society in Latin America. Agencies like USAID and the National Endowment for Democracy funded judicial training, election monitoring, and anti-corruption programs. Brazil’s Superior Electoral Court became a regional model—and one of the strongest institutions of its kind anywhere. Those same institutions are what made it possible to hold Bolsonaro accountable.
Meanwhile, over those same decades, the United States dismantled many of the guardrails that once constrained executive power. A doctrine of presidential immunity, once fringe, was normalized by the courts. And now, in a surreal twist, the Trump administration is punishing Brazil with unprecedented tariffs and sanctions for what Trump calls a “witch hunt” against Bolsonaro. A country that once lectured the world about the rule of law is now undermining a major democracy for insisting on legal accountability for crimes against the established order.
History helps explain why Brazil could act while the U.S. could not. The country has a long record of coups— every one of them, as historian Carlos Fico notes, instigated by the armed forces. The most consequential was the 1964 coup, which toppled President João Goulart and installed a military dictatorship that lasted until 1985. That regime tortured dissidents, censored the press, and ruled through decrees. But when it fell, Brazil embarked on a remarkable, if imperfect, democratic experiment. The 1988 Constitution, among the most participatory in the world, guaranteed expansive civil, political, and social rights. It also deliberately strengthened the judiciary as a counterweight to future authoritarian temptations by a strong executive branch. Unlike Argentina, Brazil never pursued full transitional justice—agents of the state responsible for gross human rights violations were granted amnesty—but it did invest heavily in building courts that were independent and willing to take on politicians. The result is a judiciary far more assertive than most of its Latin American neighbors, and, ironically, more assertive than its U.S. counterpart when it comes to disciplining presidents.
This assertiveness showed up long before Bolsonaro. In the 2010s, Brazil’s judiciary presided over Operation Car Wash, a sprawling anti-corruption probe that implicated business leaders and politicians from virtually every major party. In its wake, a reactionary backlash grew that paved the way for the impeachment of President Dilma Rousseff —Lula’s hand-picked successor elected in 2010—and the imprisonment of Lula himself in 2018. If these interventions sometimes destabilized democracy, creating the very conditions that made Bolsonaro’s election possible, they also cemented a principle: no leader was above the law. In the United States, by contrast, courts and prosecutors have grown ever more cautious about touching the presidency, adopting the idea that extraordinary deference is needed to avoid “politicization.” Notwithstanding the opinion of the current majority on the Supreme Court, impunity is not written in the Constitution. It is a choice—and one that has hollowed out accountability.
Party politics matter too. Brazil’s right-wing is fragmented across several parties. Despite his demonstrable political endurance, Bolsonaro does not occupy the same role on the Brazilian right that Trump does in the U.S. context. There are plenty of center-right and reactionary candidates lining up in Brazil to try to inherit Bolsonaro’s base of support. Faced with a rigid two-party system, Republicans, for their part, had every incentive to circle the wagons when Trump found himself in legal jeopardy. For other Republicans to admit Trump’s guilt would have been to admit to a form of complicity. For most, loyalty to the party outweighed loyalty to the Constitution. Brazil is polarized too, but its divides are not as locked into a binary trench warfare. Its political alignments have shifted over time, allowing institutions more room to maneuver. In the United States, polarization has hardened into an identity war—where accountability itself is framed as partisan revenge.
Trump has stumbled badly in trying to manage the fallout of Bolsonaro’s conviction. At first, he lashed out—slapping tariffs on Brazilian exports, sanctioning judges, and loudly denouncing Lula. The strategy backfired. It boosted Lula’s standing and pushed Brazil’s business community into his corner. Trump ended up isolating the very people he expected to bolster. Given a long list of exemptions, Brazil’s economy has weathered the sanctions better than expected, and Lula suddenly looked stronger—not weaker—on the world stage. The Trump administration now appears to be laying the groundwork for a quiet retreat, sending envoys to Brasília and orchestrating a brief meet-and-greet with Lula at the United Nations. Trump will almost certainly continue talking tough in public, hailing Bolsonaro and casting him as a victim of judicial tyranny. Behind the scenes, however, their interests are likely to begin to diverge.
Brazil faced a serious test—and its institutions passed. Even with Bolsonaro’s family gearing up for 2026 and polarization running deep, the courts acted decisively, showing that a democracy can prosecute an antidemocratic leader without collapsing. That is the contrast with the United States. For decades, Washington exported democracy abroad. It may be time to import some of those lessons back home. There is no need to reinvent the wheel. The United States must, however, stop treating itself as exceptional and start learning from countries that have faced down antidemocratic threats and won. Brazil is one of them. Its transition from dictatorship to democracy was fragile, and its institutions were painstakingly built to withstand precisely the kind of erratic authoritarian Bolsonaro turned out to be. The fact that they held should not be dismissed as luck. It was the result of design, reform, and persistence.
Comparing the U.S. and Brazil is a reminder that democracy has to be actively defended, and that rules alone aren’t enough. Brazil’s institutions didn’t stumble or hedge; they acted, even in a deeply polarized moment, proving that accountability is possible when courts, prosecutors, and political actors are willing to uphold the law. The United States, by contrast, let partisanship and polarization dictate how—or whether—violations were punished, showing with stunning clarity how impunity takes root. The lesson is clear: strong institutions, a culture of accountability, and the political will to enforce democratic norms mark the difference between resilience and erosion. Brazil’s example isn’t perfect, but it is instructive: democracies survive not by chance, but by determination.
Cover photo: Former Brazilian President (2019-2022) Jair Bolsonaro leaves the DF Star hospital in Brasilia on September 14, 2025, after undergoing a series of medical examinations. Brazil’s Supreme Court on September 11 sentenced firebrand ex-president Jair Bolsonaro to 27 years in prison for coup plotting at the end of a landmark trial that divided the nation and drew US fury. (Photo by Sergio Lima / AFP)
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