Settling Up: A Short History of Moving On

On Wednesday I drew a map of grace and accountability and said this country has a habit: when public power is abused, we forgive first and account never. Yesterday I wrote about what we rehearse in the pause. I promised the receipts. Here they are, and Tuesday added a few.

The ledger

1862. Months before the Emancipation Proclamation, Congress freed the enslaved people of the District of Columbia and paid their enslavers up to $300 for each person set free (U.S. Senate, n.d.). The people who had been enslaved were paid nothing. Grace, for the wrong party.

1865. In January, General William T. Sherman's Special Field Order No. 15 set aside about 400,000 acres of coastline from Charleston to Florida's St. Johns River to be divided into forty-acre plots for freed families. By that fall, President Andrew Johnson had overturned it, and most of the land went back to the planters (New Georgia Encyclopedia, n.d.).

1865–1868. Johnson pardoned former Confederates by proclamation, ending with a general "Christmas amnesty" on December 25, 1868. Jefferson Davis, the Confederacy's president, was released on bail in 1867, and the treason charges against him were dropped in 1869. He was never tried. Reconstruction itself was abandoned in 1877.

1945–1949. Operation Paperclip brought Nazi scientists to work for the United States. Declassified U.S. records show that the leaders of Japan's Unit 731, which ran human experiments, were granted immunity from prosecution in exchange for their research data (Santa Clara University, 2024).

1974. Gerald Ford pardoned Richard Nixon before any charges were filed. Left alone, Ford said, the case "could go on and on and on, or someone must write the end to it" (Ford, 1974). The country learned instead how cheaply power reads forgiveness without accounting.

2021–2025. After January 6, the Senate voted 57 to 43 to convict Donald Trump, ten votes short of the two-thirds required (NPR, 2021). The courts did the slower work, case by case, for four years. Then, on January 20, 2025, his first day back in office, Trump pardoned roughly 1,500 people charged in the attack and commuted the sentences of 14 more, including people convicted of attacking police officers (Associated Press, 2025).

The rioters had acted in his name, and the man they acted for wiped the slate. The ten House Republicans who voted to impeach him paid instead. Eight were gone after 2022, retired or beaten in primaries; on Tuesday David Valadao lost his seat, and Dan Newhouse is retiring, so none of the ten will sit in the next Congress (Bhakta, 2026). Accountability had a price, and the people who asked for it paid it.

A relay of deferrals, 2016–2024. This one runs through Kentucky. In 2016, after Justice Antonin Scalia died, Mitch McConnell refused for nearly ten months to give President Obama's nominee, Merrick Garland, so much as a hearing; the seat, he said, belonged to the next president (NBC News, 2016). In 2020 he confirmed Amy Coney Barrett eight days before an election (Mascaro, 2020). In February 2021, he voted to acquit Trump on a technicality (the president had already left office) and then, minutes later, called him "practically and morally responsible" for January 6 (McConnell, 2021).

The Senate, he said, could leave it to the criminal and civil courts: former presidents, he promised, "are not immune from being accountable by either one." The criminal case fell to Attorney General Merrick Garland, the same Garland, whose Justice Department took nearly two years to appoint a special counsel, Jack Smith, in November 2022 (Johnson & Lucas, 2022). By the time that case reached the Supreme Court, the Court that McConnell built was ready to answer it, and its answer was immunity.

2024. In Trump v. United States, the Supreme Court ruled 6 to 3 that a former president has absolute immunity from criminal prosecution for his core constitutional acts, and at least presumptive immunity for his other official acts (Trump v. United States, 2024). The accounting now had a constitutional ceiling.

The same morning, January 20, 2025. Hours before Trump's pardons, Joe Biden, in his last hours in office, issued preemptive pardons to Dr. Anthony Fauci, Gen. Mark Milley, the members and staff of the House January 6 committee, the police officers who testified to it, and five members of his own family, weeks after pardoning his son Hunter (Parloff, 2025; Garrett et al., 2024). He said he was protecting people from promised retribution, not excusing wrongdoing, and the motive matters. But the tool was the same one: clemency without process, in bulk, at the end of a term.

Not neutral means saying so about my own side too. (And now the accounting runs backward. Trump's pardon attorney, Ed Martin, wrote last year to the House Oversight chairman, Kentucky's own James Comer, that his office "cannot support the validity" of pardons Biden signed by autopen, and Pam Bondi, then attorney general, opened a review (Tapper, 2025; Axios, 2025). A pardon that can be revoked by the next president isn't mercy or accountability. It's a weapon with a timer.)

Notice what never changed in that ledger: the law. The Constitution's pardon clause reads the same in 2025 as it did in 1865. What changed was the procedure around it, the practice that filled the gaps, and the precedent each practice left for the next president. The law didn't change; the practice did, and practice has a way of becoming precedent.

Every earlier entry in this ledger is grace without accounting. The last one is different. The accounting happened, and then it was undone.

A sentence served is not a pardon

Some people answer this by pointing out that people reoffend after prison too. They do; about half of people released from federal prison are rearrested within eight years (U.S. Sentencing Commission, 2021). People who care about justice reform, me included, argue against judging anyone by that number alone.

But those are two different things. Someone who has served a sentence has paid what was owed; what they do next is a new chapter. A pardon handed out in bulk to people who acted in your name, with no individual review, is a receipt with the total erased. It tells them there was nothing to account for. That inverts an old idea. In 1915 the Supreme Court wrote that a pardon carries "an imputation of guilt," and that accepting one is "a confession of it" (Burdick v. United States, 1915). Lawyers today mostly read that as an aside, not binding law. But the instinct behind it is the yes-and: grace presumes there was something to forgive.

At least one person who was offered that grace understood it. Pamela Hemphill, 71, pleaded guilty to a misdemeanor for her part in January 6 and served 60 days in jail. When the pardon came, she turned it down. "I broke the law that day — period, black and white," she told NPR. "I'm not a victim. I'm a volunteer" (Bartlam et al., 2025). Accepting it, she said, would suggest what she did was acceptable, and she wouldn't be part of rewriting that day. That's the yes-and, from the inside: she had already done her accounting, and she wouldn't let anyone erase it.

At least 97 of the January 6 pardon recipients have been arrested for, charged with, or convicted of other crimes (Lawfare, 2026). Most of that conduct came before the pardons, and the count is almost certainly incomplete. But since the pardons, at least a dozen have been charged with new offenses (CREW, 2026). One, Christopher Moynihan, pleaded guilty in February to threatening to kill House Minority Leader Hakeem Jeffries (Spectrum News, 2026). Those weren't accidents of mercy. They were what grace without accountability makes room for.

Who pays when the debt is forgiven

Restitution is accountability made concrete: money a court orders paid to the people who were harmed. Thomas Franco put almost $4 million into Carlos Watson's Ozy Media, a company that turned out to be largely an illusion. A jury convicted Watson of fraud, and a judge ordered him to repay investors almost $37 million. Hours before Watson was due to report to prison, the president commuted his sentence, and the restitution went with it. "Authority and accountability," Franco told CBS News, "are two very different things" (Kaminsky et al., 2026).

He's one of many. A CBS News investigation of more than 160 of Trump's clemency orders, not counting the January 6 grants, found that they erased at least $119 million in restitution owed to victims, from family food businesses and community banks to the IRS. Another $120 million in fines will never reach the federal Crime Victims Fund, which pays for victims' medical bills, counseling and shelters. Count the restitution prosecutors had asked for before a judge could rule, including $660.8 million they argued Trevor Milton of Nikola owed his victims (Milton and his wife had given almost $3 million to groups backing Trump's reelection five months before his pardon), and the total passes $1.1 billion. For comparison, Joe Biden's clemency erased about $14,000 in four years, because most of his grants were commutations that left financial penalties in place (Kaminsky et al., 2026).

Some recipients took money back. Joseph Schwartz ran more than 100 nursing homes before his company collapsed; workers say it took health insurance premiums out of their paychecks and never paid the insurers. He paid nearly $1 million to a lobbying firm tied to Jack Burkman and Jacob Wohl, and the president pardoned him three months into a three-year sentence. "There was no restitution at all for any of his victims," said Theresa Dante, a cook at one of his homes (Kaminsky et al., 2026).

On the Capitol itself: the mob caused almost $3 million in damage. Rioters were sentenced to more than $1.2 million in restitution and fines, and the government recovered less than $665,000. Now some pardoned rioters are winning refunds of what they paid, and others are suing the government, among them Andrew Taake, who pleaded guilty to assaulting officers with bear spray and is seeking $2.5 million (Reinhard et al., 2026). A bill from Senators Alex Padilla and Sheldon Whitehouse to block those payouts has no Republican co-sponsors.

When the offender is forgiven the debt, the victim pays it.

Rhyme, or reminder

People like to say history doesn't repeat itself, but it rhymes, and they like to credit Mark Twain. He never said it; the earliest solid source is the psychoanalyst Theodor Reik, in 1965 (Quote Investigator, 2014). I'd put it my own way: history may not repeat, but it reminds us of the lessons we've forgotten.

The bill coming back with interest is the reminder. And a rhyme is only useful if it reminds. If it consoles us that this has all happened before and turned out fine, it becomes another pardon.

Remembering is not honoring

That's what the fight over monuments is really about. Take one down and someone says we're erasing history. But a statue isn't history. It's a decision about whom to honor. Most Confederate monuments went up in two waves: at the beginning of the Jim Crow era and again in response to the civil rights movement (Southern Poverty Law Center, 2016).

In October 2025, the National Park Service reinstalled the statue of Albert Pike in Washington, toppled by protesters in 2020 (Associated Press, 2025b). Pike was a Confederate general. Andrew Johnson pardoned him. Grace without accounting, recast in bronze.

Compare Germany, and not because Germany got it all right; Hans Globke, who co-wrote the official legal commentary on the Nuremberg race laws, ran Chancellor Konrad Adenauer's office for a decade. Germany's reckoning came late and was fought for. But it came. Hitler's Eagle's Nest above Berchtesgaden burned on October 23, apparently arson; a suspect is in custody, and his motive is unknown. Bavaria's interior minister, Joachim Herrmann, said right away that it would not be left a ruin and that the work of remembrance would continue (Associated Press, 2026). The building holds an exhibition on its Nazi history, not a statue of its owner.

I've stood on the blacktop in Berlin where Hitler's bunker was. It's a parking lot, with an information board, and that's the point. Nobody is allowed to make it a shrine.

That's the difference. Remembering keeps the bill on the table. Honoring tears it up.

Who holds the pen

On Tuesday, Kentucky passed Amendment 1, about 71 percent to 29 in unofficial returns (Horsley, 2026). It bars a governor from granting pardons, commutations or reprieves from 60 days before a gubernatorial election until the fifth Tuesday after it, when the next term begins, and it requires the reasons for each clemency decision to be on public record (Spectrum News 1, 2026). It grew out of Matt Bevin's lame-duck pardons in 2019. Its sponsor, state Sen. Chris McDaniel, a Republican, says he started the effort after a governor of his own party did it, and that no governor of either party should be able to hold those decisions until voters can no longer weigh in (Horsley, 2026).

I wrote in October about what it costs: no exception for new evidence of innocence, and a governor's grace is also how some Kentuckians get their vote back. The ACLU of Kentucky raised the same worry about wrongful and excessive sentences (LINK nky, 2026). The first governor it fences in will be Andy Beshear, in the fall of 2027, at the end of his last term. Seven in ten Kentucky voters just answered, for one office, the question this whole ledger asks at the national scale: how much should one hand hold, when, and in whose name? Washington has no window at all.

On Thursday, California showed what that window is for, and what it can't settle. Gov. Gavin Newsom, preparing to leave office after eight years, commuted all 548 of the state's death sentences to life in prison without parole, the largest clearing of a death row in modern U.S. history (Levin, 2026). That is bulk clemency at the end of a term, the very thing Kentucky just fenced off. But look at what it keeps. No one walks out; the sentences stand, and only the execution comes off the table. And he put his reasons in writing, with his name on them: "As Governor, I alone bear responsibility for this decision and its impact, just as I alone would bear responsibility for each execution" (Associated Press, 2026c). Some victims' families objected, and they have every right to. That's the yes, and in practice: grace, with the accounting left standing and the reasons on the record.

Colorado shows how tangled the pen can get. Tina Peters, a county clerk, was convicted of tampering with voting equipment to chase Trump's claims about 2020. Trump "pardoned" her in December 2025, a symbolic gesture, since a president has no power over state crimes. In May, Colorado's Democratic governor, Jared Polis, commuted her nine-year sentence to about four and a half, after an appeals court found her speech had been improperly weighed at sentencing and after she apologized and promised to follow the law. Colorado's attorney general called it "a sad day for Colorado" (NPR, 2026).

Grace from my own side, to someone who attacked the vote, conditioned on an admission. You can disagree with it, and many Democrats did, but it's closer to the yes-and than a blanket pardon will ever be. (Then the coda nobody could have scripted: this summer, Shasta County, California's registrar of voters, Clint Curtis, offered her a consulting role with his elections office. She turned it down after Gov. Gavin Newsom moved to block the transfer of her parole and Sens. Alex Padilla and Adam Schiff asked the state to keep her away from voting machines (Jefferson Public Radio, 2026). Grace with conditions only works if someone keeps watching the conditions.)

The most practical fix may be the least dramatic. Liz Oyer, the federal pardon attorney who was fired in 2025, argues that limiting the pardon power risks cutting off mercy for people who deserve it. Her answer is sunlight instead: make the president disclose clemency paperwork within 24 hours of signing it, and make recipients disclose the money paid and relationships leveraged to get it (Oyer, 2026). That keeps the door to grace open and puts the accounting where everyone can see it.

The bill comes due

Tuesday wasn't only a vote on candidates. More than half of voters told the AP Voter Poll that government corruption was crucial to their vote for Congress, a little more than said the same about the cost of living. About seven in ten said Congress hadn't done enough to check the president, including about four in ten Republicans (Associated Press, 2026b).

By Wednesday morning the new majorities were sending notice. Rep. Robert Garcia, the incoming chair of House Oversight, issued a two-word statement: "Lawyer up." Sen. Ron Wyden posted one word: "Subpoenas" (Beitsch, 2026). Rep. Bobby Scott, in line to chair the House Education and Workforce Committee, wrote to the heads of ten departments and agencies reminding them that federal law requires them to preserve the records of public business, that destroying those records can mean up to three years in prison, and asking for written assurance by November 18 (Aratani, 2026). Rep. Jamie Raskin, set to chair Judiciary, named the thread that runs through this whole post: "We can subpoena pardon brokers" (Marcus, 2026).

That's the accounting starting. It's also where the old habit shows up. On election night, Hakeem Jeffries, who is set to be the next Speaker, promised "accountability to those who have visited unprecedented corruption on this country" (Beitsch, 2026). The next morning, on Morning Joe, he put it another way: Americans, he said, don't want Democrats to "get even"; they want them to get things done (Taylor & Khardori, 2026). Both can be true; affordability is the job. But "don't get even" is what Ford's "someone must write the end to it" sounds like in 2026, and the ledger above shows what happens when the people holding the pen decide the country would rather move on.

Getting even isn't the point. Settling up is, and the difference is process. Claire Finkelstein, a law professor, argues that the lesson of two failed impeachments is patience: subpoena the inner circle, then methodically enforce the subpoenas, because "allowing presidents to control the very processes by which their own conduct is judged poses an even graver danger to democracy than straightforward presidential law-breaking" (Finkelstein, 2026). It won't be quick. The Supreme Court's rulings in Trump v. Mazars (2020) and Trump v. United States (2024) "will be enormously powerful for Trump and his allies to use to at least stall the investigations," Jonathan Shaub, a University of Kentucky law professor who served in Biden's White House counsel's office, told The New Yorker (Marcus, 2026). Stalling is just deferral with a lawyer.

Some people aren't waiting for January. The Rule of Law Project, a group of former federal prosecutors and FBI agents led by Mark Blumberg, who spent nearly 30 years prosecuting cases for the Justice Department's Civil Rights Division, is building case files now: witness statements, documents and draft memos for prosecutors at every level. Criminal cases have statutes of limitations, he said, and the point is to give prosecutors "the gift of time" (Taylor & Khardori, 2026). Time is the currency deferral spends. Somebody is finally saving some.

Settling up

None of this is a case for cruelty. Grace and accountability were never an either/or; they're a yes, and. Grace opens the door. Accountability walks through it. Repair is what we build on the other side.

But you can't build on a debt you've agreed to forget. Settling up isn't revenge, and it isn't getting even. It's how a country stops paying the same bill with interest, generation after generation. Tuesday handed the pen to new hands. The question is whether they'll write the end to it, again, or finally write it down.

In December I'll take this one step further, to the hoarding underneath it all, in Compost the Rich.

Start here if you missed it: Recess Is Revolution, then The Rehearsal Is the Real Thing.

References

Aratani, L. (2026, November 4). Democrats warn Trump officials to keep records or risk criminal penalties after midterm victories. The Guardian. https://www.theguardian.com/us-news/2026/nov/04/democrats-warn-trump-officials-preserve-records

Associated Press. (2025, January 20). Trump issues sweeping pardon of 1,500 Jan. 6 defendants, including rioters who attacked police (via Anchorage Daily News). https://www.adn.com/nation-world/2025/01/20/trump-issues-sweeping-pardon-of-1500-jan-6-defendants-including-rioters-who-attacked-police/

Associated Press. (2025b, October 27). A Confederate statue toppled in Washington, D.C., in 2020 has been reinstalled (via High Plains Public Radio). https://www.hppr.org/2025-10-27/a-confederate-statue-toppled-in-washington-d-c-in-2020-has-been-reinstalled

Associated Press. (2026, October 24). Fire largely destroys Hitler's former Eagle's Nest retreat in Germany (via The Spokesman-Review). https://www.spokesman.com/stories/2026/oct/24/fire-largely-destroys-hitlers-former-eagles-nest-r/

Associated Press. (2026b, November 4). How Trump and Republicans lost the 2026 midterm elections, according to AP Voter Poll (via PBS News). https://www.pbs.org/newshour/politics/how-trump-and-republicans-lost-the-2026-midterm-elections-according-to-ap-voter-poll

Associated Press. (2026c, November 5). Newsom says he will commute all 548 of California's death sentences to life without parole (via PBS News). https://www.pbs.org/newshour/politics/newsom-says-he-will-commute-all-548-of-californias-death-sentences-to-life-without-parole

Axios. (2025, October 28). AG Pam Bondi reviewing Biden pardons signed by autopen. https://www.axios.com/2025/10/28/biden-autopen-bondi-investigation-oversight

Bartlam, T., Ketchum, J., & Shapiro, A. (2025, January 23). Why a Jan. 6 defendant rejected Trump's pardon. NPR. https://www.npr.org/transcripts/g-s1-44457

Beitsch, R. (2026, November 5). Democrats signal oversight blitz as Trump officials lawyer up. The Hill. https://thehill.com/homenews/house/6199505-house-investigations-trump-administration/

Bhakta, M. (2026, November 4). None of the House Republicans who voted to impeach Trump will be in the next Congress. The Hill. https://thehill.com/homenews/house/6199833-trump-impeachment-vote-republicans-exit/

Burdick v. United States, 236 U.S. 79 (1915). https://www.govinfo.gov/content/pkg/USREPORTS-236/pdf/USREPORTS-236-79.pdf

Citizens for Responsibility and Ethics in Washington. (2026, June 3). At least 40 pardoned insurrectionists face other criminal charges, with 12 offending since Trump's pardon. https://www.citizensforethics.org/reports-investigations/crew-reports/at-least-33-pardoned-insurrectionists-face-other-criminal-charges-but-many-are-now-going-free/

Finkelstein, C. (2026, November 4). Democrats won. What does that mean for impeachment inquiries? The Guardian. https://www.theguardian.com/commentisfree/2026/nov/04/democrats-congress-trump

Ford, G. R. (1974, September 8). Remarks on signing a proclamation granting pardon to Richard M. Nixon. The American Presidency Project. https://www.presidency.ucsb.edu/documents/remarks-signing-proclamation-granting-pardon-richard-nixon

Garrett, L., Lucas, R., & Johnson, C. (2024, December 1). President Biden pardons son Hunter. NPR (via High Plains Public Radio). https://www.hppr.org/2024-12-01/president-biden-pardons-son-hunter

Horsley, M. (2026, November 4). Amendment to curtail governor's pardon power wins by large margin. Kentucky Lantern (via The News-Enterprise). https://www.thenewsenterprise.com/news/state/amendment-to-curtail-governor-s-pardon-power-wins-by-large-margin/article_ba6e708d-0421-5eb1-ae9b-461d2f203859.html

Jefferson Public Radio. (2026, September 1). Tina Peters rejects Shasta County elections job offer. https://www.ijpr.org/politics-government/2026-09-01/tina-peters-shasta-county-election-job-offer

Johnson, C., & Lucas, R. (2022, November 18). DOJ names Jack Smith as special counsel to oversee Trump criminal investigations. NPR (via WAMC). https://www.wamc.org/2022-11-18/doj-names-jack-smith-as-special-counsel-to-oversee-trump-criminal-investigations

Kaminsky, G., Reilly, S., & Klaidman, D. (2026, October 27). In Trump's pardon economy, crime victims lost out on at least $119 million in restitution. CBS News. https://www.cbsnews.com/projects/2026/trump-pardon-economy-investigation/

Lawfare. Pompilio, K. (2026, June 4). The Jan. 6 pardons: How many clemency recipients have faced other charges? https://www.lawfaremedia.org/article/the-jan-6-pardons--how-many-clemency-recipients-have-faced-other-charges

Levin, S. (2026, November 5). Gavin Newsom commutes more than 500 death sentences in California. The Guardian. https://www.theguardian.com/us-news/2026/nov/05/gavin-newsom-commutes-death-sentences-california

LINK nky. (2026, November 3). Kentucky votes 'Yes' on Amendment 1 restricting governor's pardon powers. https://linknky.com/elections/2026/11/03/kentucky-votes-yes-on-amendment-1-restricting-governors-pardon-powers/

Marcus, R. (2026, November 4). Washington lawyers up. The New Yorker. https://www.newyorker.com/news/the-lede/washington-lawyers-up

Mascaro, L. (2020, October 26). Barrett confirmed as Supreme Court justice in partisan vote. Associated Press (via GBH). https://www.wgbh.org/news/national/2020-10-26/barrett-confirmed-as-supreme-court-justice-in-partisan-vote

McConnell, M. (2021, February 13). Floor remarks after the impeachment vote (as reported by Axios). https://www.axios.com/2021/02/13/mcconnell-condemns-trump-responsible

NBC News. (2016). Merrick Garland now holds the record for longest Supreme Court wait. https://www.nbcnews.com/news/us-news/merrick-garland-now-holds-record-longest-supreme-court-wait-n612541

New Georgia Encyclopedia. (n.d.). Sherman's Field Order No. 15. https://www.georgiaencyclopedia.org/articles/history-archaeology/shermans-field-order-no-15/

NPR. (2021, February 13). Senate acquits Trump: Key takeaways from impeachment trial. https://www.npr.org/2021/02/13/967704462/senate-acquits-trump-key-takeaways-from-impeachment-trial

NPR. (2026, May 15). Colorado's Democratic governor will let Trump ally Tina Peters out of prison early (via High Plains Public Radio). https://www.hppr.org/npr-news/2026-05-15/colorados-democratic-governor-will-let-trump-ally-tina-peters-out-of-prison-early

Oyer, L. (2026, September 8). Trump's secret pardons. Lawyer Oyer. https://www.lawyeroyer.com/p/trumps-secret-pardons

Parloff, R. (2025, January 20). Biden grants preemptive pardons to Milley, Fauci, and others. Lawfare. https://www.lawfaremedia.org/article/biden-grants-preemptive-pardons-to-milley--fauci--and-others

Quote Investigator. (2014, January 12). History does not repeat itself, but it rhymes. https://quoteinvestigator.com/2014/01/12/history-rhymes/

Reinhard, B., Silverman, E., & Schaffer, A. (2026, January 21). They ransacked the US Capitol and want the government to pay them back. The Washington Post (via The Boston Globe). https://www.bostonglobe.com/2026/01/21/nation/jan-6-refunds/

Santa Clara University. (2024). Post-war cover-up and legacy [Digital exhibit on Unit 731]. https://dh.scu.edu/exhibits/exhibits/show/world-war-ii-2024/cc-page/post-war-cover-up-and-legacy

Southern Poverty Law Center. (2016, April 21). SPLC study finds more than 1,500 government-backed tributes to the Confederacy across U.S. https://splcenter.org/news/2016/04/21/splc-study-finds-1500-government-backed-tributes-confederacy-across-us

Spectrum News. (2026, February 6). N.Y. man pleads guilty to threatening to kill Hakeem Jeffries. https://spectrumlocalnews.com/nys/central-ny/politics/2026/02/06/n-y--man-pleads-guilty-to-threatening-to-kill-hakeem-jeffries

Spectrum News 1. Brighton, M. (2026, October 20). Kentucky voters to decide limits on governor's pardon power. https://spectrumnews1.com/ky/louisville/news/2026/10/15/governor-pardon-power-constitutional-amendment-explainer

Tapper, J. (2025, October 28). Read: Justice Department attorney Ed Martin's email on Biden-era pardons. CNN (via KEYT). https://keyt.com/?p=1353427

Taylor, M., & Khardori, A. (2026, November 4). We're not waiting for January. Investigations into Trump's corruption begin now! [Video episode, with Mark Blumberg; includes a clip of Hakeem Jeffries on Morning Joe]. Defiance. https://www.defiance.news/p/were-not-waiting-for-january-investigations

Trump v. United States, 603 U.S. 593 (2024). https://www.supremecourt.gov/opinions/slipopinion/23

U.S. Senate. (n.d.). The District of Columbia Compensated Emancipation Act. https://www.senate.gov/artandhistory/history/common/generic/DCEmancipationAct.htm

U.S. Sentencing Commission. (2021). Recidivism of federal offenders released in 2010. https://www.ussc.gov/research/research-reports/recidivism-federal-offenders-released-2010