A human rights activist and critic of the Kremlin, Anna Politkovskaya was shot dead in an elevator of her apartment building in Moscow as she was returning home. Politkovskaya investigated human rights abuses in Chechnya and high-level corruption across Russia, and her death raised concerns about the safety of journalists and other critics of the government. Because she was a critic of Russian governmental policies, it was widely speculated at the time of her murder that the Russian government was involved. At the time she was working for the low-circulation independent newspaper Novaya Gazeta [official website, in Russian] where she was writing reports on Chechnya. Her death was widely believed to be a contract killing. Russia's Federal Security Service charged Rustam Makhmudov for the murder [JURIST report] in June 2011. Two of Makhmudov's brothers and a former police officer are currently awaiting trial for the murder in Moscow. A district court acquitted those three men in February 2009 due to a lack of prosecutorial evidence, but the Russian Supreme Court vacated the acquittal and ordered a reinvestigation of the case [JURIST reports].

The House Committee on Foreign Affairs approved [JURIST report] an early version of the bill in June. Following the approval, Committee Chairwoman Ileana Ros-Lehtinen stated, "[The bill] requires that those responsible for the death, torture, or repression of individuals investigating crimes by Russian government officials, or who were simply trying to exercise their basic human rights, be publicly named and sanctioned." Prior to his death, Magnitsky was held in prison for 358 days with little to no access to legal representation, his family or medical professionals. In a controversial move last August, Russian investigators reopened the case [JURIST report] against Magnitsky on the basis of a new ruling permitting criminal cases against the dead. Critics of this action, such as JURIST Contributing Editor David Crane, argue that the ongoing posthumous prosecution of Magnitsky is a violation of the rule of law [JURIST op-ed] and an embarrassment for the Russian judicial system.