Civil rights advocates and lawmakers have long said that Mr. Garvey’s 1923 conviction for mail fraud was unjust, arguing that he was targeted for his work.

It's not clear whether Biden, who leaves office Monday, will pardon people who have been criticized or threatened by President-elect Donald Trump.

President Biden on Sunday pardoned Marcus Garvey, one of the first Black civil rights leaders, more than 80 years after Garvey’s death.