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.

This historic pardon culminates a decades-long fight by Marcus Garvey’s descendants and supporters to right the wrongs of a what many regarded as a politically motivated conviction.

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