By Xenom 
I watched closely as President Joe Biden pardoned Garvey, Ragbir, and Smith Pradia on January 19, 2025, his final full day in office. These presidential clemency grants mark some of the most meaningful acts of executive power in recent American memory, touching on racial justice, immigrant rights, and criminal justice reform.
Many folks have been asking what made these particular pardons stand out among Biden’s record-breaking clemency actions. Let me walk you through the complete story.
The Final Presidential Clemency Batch
That January day, Biden issued five pardons and commuted two sentences, bringing his total individual clemency acts to a staggering 4,245—more than any other US president on record.
The three most notable pardons went to:
- Marcus Mosiah Garvey (a posthumous pardon for the Black nationalist leader)
- Ravidath “Ravi” Ragbir (an immigrant rights activist facing deportation)
- Kemba Smith Pradia (a criminal justice reform advocate previously given sentence commutation)
Each pardon tells a unique American story spanning nearly a century of legal struggles, social movements, and personal redemption.
Marcus Garvey’s Pardon: Correcting a Century-Old Injustice
The Pan-African Pioneer
Marcus Garvey built a global movement that changed Black history forever. As a Jamaican immigrant, he:
- Founded the Universal Negro Improvement Association (UNIA) in 1914
- Created the Black Star Line shipping company for Black economic empowerment
- Built a movement with millions of members across dozens of countries
- Promoted Pan-Africanism, Black self-reliance, and economic independence
- Inspired countless civil rights leaders for generations to come
Dr. Martin Luther King Jr. once called Garvey “the first man of colour in the history of the United States to lead and develop a mass movement” who gave millions of Black people “a sense of dignity and destiny.”
The Politically Motivated Prosecution
The US government’s case against Garvey raised serious questions about justice from the start:
- J. Edgar Hoover personally targeted Garvey, labelling him a “notorious negro agitator”
- The FBI employed its first Black agent specifically to infiltrate Garvey’s organisation
- The trial judge had known ties to the NAACP, which actively opposed Garvey
- A key prosecution witness later admitted to perjury, claiming prosecutors instructed him to lie
- The conviction relied heavily on circumstantial evidence about mail fraud
After his 1923 conviction, Garvey received the maximum sentence: five years imprisonment and a £1,000 fine. President Calvin Coolidge commuted his sentence in 1927, but this led to Garvey’s immediate deportation as an “undesirable alien.”
A Decades-Long Fight for Justice
The pardon campaign took remarkable persistence. Dr. Julius Garvey, Marcus’s son, pushed for over 15 years to clear his father’s name. He worked alongside Professor Justin Hansford of Howard University School of Law and gained crucial support from the Congressional Black Caucus.
Dr. Julius Garvey expressed profound relief at the pardon, viewing it as a way to “rehabilitate my father’s name against the slander of a criminal conviction.” Former Attorney General Eric Holder described the pardon as correcting “a grave historical wrong.”
The White House statement explicitly acknowledged Garvey as a “renowned civil rights and human rights leader” whose conviction stemmed from “injustice.”
Ravi Ragbir’s Pardon: Protecting Free Speech for Immigrants
From Conviction to Activism
Ravi Ragbir’s journey embodies the complexity of American immigration policy. After arriving from Trinidad and Tobago in 1991, he:
- Became a lawful permanent resident in 1994
- Worked at a mortgage lending company where fraud occurred
- Received a 30-month sentence for wire fraud in 2001
- Faced deportation as his conviction qualified as an “aggravated felony”
- Transformed his life to become a nationally recognised immigrant rights leader
After serving his sentence, Ragbir co-founded the New Sanctuary Coalition of New York City, an interfaith organisation supporting immigrants facing deportation. He received numerous awards for his advocacy and was appointed Ecumenical Canon for Immigration Justice by the Episcopal Diocese of Long Island.
The First Amendment Showdown
What made Ragbir’s case extraordinary was the allegation that immigration authorities targeted him for deportation because of his activism criticising government policies.
In January 2018, during a routine ICE check-in, officials suddenly detained Ragbir and flew him to a detention centre in Florida. This sparked mass protests in New York City.
A federal judge ordered his release, calling his detention “unnecessarily cruel” and noting Ragbir had “lived the life of a redeemed man.”
His legal team won a groundbreaking ruling from the US Court of Appeals for the Second Circuit in 2019, establishing that non-citizens may possess First Amendment protection from retaliatory deportation based on their protected speech.
A Coalition of Support
The pardon came after years of tireless advocacy from an impressive coalition:
- The NYU Immigrant Rights Clinic represented him for 17 years
- The original federal sentencing judge supported clemency
- The federal prosecutor’s office in New Jersey backed the pardon
- Faith leaders across denominations advocated for him
- Political supporters included Senator Chuck Schumer, Senator Cory Booker, and Representative Alexandria Ocasio-Cortez
After receiving the pardon, Ragbir described feeling “so light and so free” after living under the constant threat of deportation for almost two decades.
Kemba Smith Pradia’s Pardon: Freedom from the War on Drugs
A College Student Ensnared
Kemba Smith’s story highlights the human cost of harsh drug sentencing laws. As a Hampton University student, her life changed dramatically when she:
- Became involved with Peter Hall, who led a drug trafficking ring
- Endured physical, mental, and emotional abuse in the relationship
- Never personally handled, used, or sold drugs
- Supported Hall through various activities within the conspiracy
- Got convicted in 1995 and sentenced to 24.5 years without parole
At sentencing, Smith was 24 years old and seven months pregnant. Though a first-time, non-violent offender, mandatory sentencing guidelines gave the judge little discretion to consider her circumstances or the role of domestic violence.
From Prison to Advocacy
President Bill Clinton commuted Smith’s sentence in December 2000, allowing her release after serving 6.5 years. She then:
- Completed her bachelor’s degree in social work
- Graduated from law school
- Founded the Kemba Smith Foundation for criminal justice reform
- Became a nationally recognised speaker on sentencing reform and domestic violence
- Served on the Virginia Sentencing Commission and Virginia Parole Board
Her story became emblematic of the “girlfriend problem” in federal drug prosecutions, where women in abusive relationships receive disproportionately harsh sentences under conspiracy laws.
Beyond Commutation to Full Pardon
While Clinton’s commutation freed Smith Pradia, the felony conviction remained on her record with numerous “collateral consequences” affecting employment, insurance, volunteering in schools, and international travel.
The NAACP Legal Defense Fund described this situation as relegating her to a form of “second-class citizenship.”
Smith Pradia called the pardon “not only an expungement of my criminal record and restoration of my rights but also a reaffirmation that our past does not define our future.”
Understanding the Broader Context of Biden’s Clemency Actions
Biden’s clemency record tells a complex story of justice reform:
- Unprecedented volume: 80 individual pardons and 4,165 commutations
- Late-term concentration: 96% of grants came in his final fiscal year
- Policy focus: Addressing injustices from the War on Drugs era
- Categorical actions: Mass pardons for simple marijuana possession and for LGBTQ+ service members convicted under military law
The pardons of Garvey, Ragbir, and Smith Pradia stand apart from some of Biden’s more controversial clemency actions, including pardons for his son Hunter Biden and preemptive pardons for family members and political allies.
The Multifaceted Power of Presidential Pardons
These three cases demonstrate how executive clemency can serve distinct but crucial functions:
- Historical correction: Garvey’s pardon addresses a politically motivated conviction from a century ago
- Constitutional protection: Ragbir’s pardon affirms First Amendment rights for non-citizens
- Systemic reform recognition: Smith Pradia’s pardon acknowledges the excessive harshness of mandatory minimum sentences
All three pardons emphasise rehabilitation, community contribution, and the value of second chances.
Common Questions About Biden’s Historic Pardons
What exactly does a presidential pardon do?
A presidential pardon forgives a federal criminal conviction, removing civil disabilities like restrictions on voting, jury service, or firearm ownership. Unlike commutation, which only reduces the sentence, a pardon addresses the conviction itself.
How many clemency actions did Biden issue in total?
President Biden granted 4,245 individual clemency actions, including 80 pardons and 4,165 commutations. This sets a record for the most individual clemency acts by any US president.
What evidence suggests Garvey’s conviction was unjust?
Historians and legal scholars point to several troubling aspects: FBI Director J. Edgar Hoover’s personal targeting of Garvey, the trial judge’s connections to Garvey’s political opponents, questionable evidence, witness perjury allegations, and the clear political motivation to silence a powerful Black leader.
How did Ragbir’s pardon relate to free speech?
Ragbir’s case established an important legal precedent when the Second Circuit Court recognised that non-citizens may have First Amendment protection against retaliatory deportation. His pardon affirms that immigrants should not face deportation for exercising free speech rights.
What is the “girlfriend problem” highlighted by Smith Pradia’s case?
The “girlfriend problem” refers to how women in relationships with drug dealers often receive disproportionately harsh sentences under conspiracy laws. These women, frequently victims of domestic violence, lack the insider information to provide “substantial assistance” to prosecutors, resulting in severe mandatory sentences.
Can these pardons be reversed by future presidents?
No. Once a presidential pardon is granted and accepted, it cannot be revoked, even by subsequent administrations. It represents a final constitutional act by the executive branch.
The Lasting Legacy of Biden’s Pardon Decisions
These three pardons represent more than just legal relief for individuals. They acknowledge systemic issues within American justice:
- Garvey’s pardon confronts the historical weaponisation of law against Black leaders
- Ragbir’s pardon challenges the use of immigration enforcement to silence political dissent
- Smith Pradia’s pardon recognises the excessive punishment of the War on Drugs era
Through these actions, Biden pardoned Garvey, Ragbir, and Smith Pradia in ways that may shape clemency decisions for generations to come, offering both personal redemption and broader social commentary on what justice truly means in America.