President Joe Biden has posthumously pardoned Black nationalist Marcus Garvey, who influenced Malcolm X and other Black civil rights leaders and was convicted of mail fraud in the 1920s. Also receiving pardons Sunday were a top Virginia lawmaker and advocates for immigrant rights, criminal justice reform and gun violence prevention. It’s not clear whether Biden, who leaves office Monday, will pardons people who've been criticized or threatened by President-elect Donald Trump. Issuing preemptive pardons would stretch the powers of the presidency in untested ways. A pardon relieves a person of guilt and punishment.