The Claim

Pardoned pro-life Americans wrongly targeted by the Biden Administration.

The Claim, Unpacked

What is literally being asserted?

That the Trump administration issued pardons to Americans prosecuted for pro-life activity during the Biden presidency, and that these prosecutions were illegitimate — “wrongly targeted” implies the prosecuted individuals did nothing that warranted criminal charges.

What is being implied but not asserted?

That the Biden DOJ engaged in political persecution — weaponizing the legal system against people whose only offense was holding pro-life views. That these were peaceful protesters punished for their beliefs rather than their conduct. That pardoning them corrects an injustice. The framing invites the reader to imagine people arrested for praying outside clinics or holding signs, not people convicted of forcible entry, physical obstruction using chains and locks, injuring staff, or conspiring to deprive patients of their civil rights.

What is conspicuously absent?

What these individuals actually did. Not one of the 23 pardoned individuals was prosecuted for expressing pro-life views, holding signs, or praying. They were prosecuted for specific, documented physical acts: using fake appointments to infiltrate clinics, chaining themselves to doors with bike locks, shoving past staff (injuring a nurse), blocking patients in medical distress from reaching care, and livestreaming the obstruction. Several were convicted not just of FACE Act violations but of conspiracy against rights under 18 U.S.C. Section 241 — a federal civil rights felony originally enacted to combat Ku Klux Klan violence. Also absent: the concurrent wave of over 200 attacks on pro-life pregnancy centers and churches that the Biden DOJ largely failed to prosecute under the same statute — a genuine enforcement disparity that complicates the “wrongly targeted” narrative while also failing to exonerate the pardoned individuals’ conduct.

Evidence Assessment

Established Facts

President Trump pardoned 23 individuals convicted of FACE Act violations on January 23, 2025 — the eve of the March for Life rally. The pardons were issued via executive clemency order. The 23 individuals were: Lauren Handy, Jonathan Darnel, Jay Smith, Paulette Harlow, Jean Marshall, John Hinshaw, Heather Idoni, William Goodman, Joan Andrews Bell, Herb Geraghty, Chester Gallagher, Calvin Zastrow, Coleman Boyd, Paul Vaughn, Dennis Green, Eva Edl, Eva Zastrow, James Zastrow, Paul Place, Caroline Davis, Joel Curry, Justin Phillips, and Bevelyn Beatty Williams. Several were incarcerated at the time of the pardon. Trump stated: “They should not have been prosecuted. Many of them are elderly people.” ¹

The pardoned individuals were convicted of specific, documented acts of physical obstruction and conspiracy against rights — not mere protest. The primary D.C. case involved ten defendants who invaded the Washington Surgi-Clinic on October 22, 2020. Lauren Handy used a false name to book a fake appointment, then admitted co-conspirators who used chains, bike locks, ropes, and their bodies to block clinic entrances. Jonathan Darnel livestreamed the blockade. Jay Smith pushed a nurse, spraining her ankle. Patients were prevented from accessing care — court documents describe one patient collapsing in pain while blocked from entering, and another climbing through a window to reach her appointment. Judge Colleen Kollar-Kotelly stated at sentencing: “That’s what you’re being punished for, not your views on abortion nor your very American commitment to peaceful protest.” Handy received 57 months; the ten D.C. defendants received a combined 23 years. ²

The FACE Act (18 U.S.C. Section 248) is a bipartisan law enacted in 1994 in direct response to anti-abortion violence, including the murder of Dr. David Gunn in 1993. The law prohibits the use of physical force, threat of force, or physical obstruction to interfere with any person obtaining or providing reproductive health services, and also protects access to places of religious worship. It was signed by President Clinton with bipartisan congressional support. Penalties range from six months to life imprisonment depending on the severity of the offense. The law was upheld by federal courts against First Amendment challenges. It protects both sides — clinic access and church access. ³

Several pardoned individuals had extensive histories of clinic invasions and arrests. Joan Andrews Bell had been arrested over 120 times for obstructing and invading reproductive healthcare clinics over decades. She has publicly stated that she believes it is “justifiable homicide” to kill abortion providers. Eva Edl, 89, a survivor of a communist concentration camp, was convicted in both the Michigan (August 27, 2020, Sterling Heights) and Tennessee (March 2021, Mt. Juliet) blockades. Heather Idoni used a bicycle lock to chain herself to a door at the Sterling Heights clinic. Chester Gallagher and Calvin Zastrow advertised planned invasions on social media and livestreamed them. Bevelyn Beatty Williams was convicted of physically obstructing access to a Manhattan Planned Parenthood over two days in June 2020, during which she crushed a staff member’s hand in the clinic door. Williams had seven prior criminal convictions. ⁴

The Biden DOJ brought approximately 24 FACE Act cases against 55 defendants, with the overwhelming majority targeting pro-life activists. Between 2021 and 2025, the DOJ charged 24 cases under the FACE Act, winning 34 convictions. Of 55 defendants, 50 were pro-life activists — approximately 91%. Only two cases were brought in defense of pregnancy resource centers attacked after the Dobbs decision, despite at least 200 documented attacks on such centers. The FACE Act was never used to defend a house of worship during the Biden administration, despite over 400 documented church attacks. This enforcement disparity is documented by both conservative and mainstream sources. ⁵

The day after the pardons, the Trump DOJ issued a memorandum effectively suspending FACE Act enforcement for clinic access. On January 24, 2025, Chad Mizelle, Chief of Staff to the Attorney General, issued a memorandum directing that “future abortion-related FACE Act prosecutions and civil actions will be permitted only in extraordinary circumstances” — defined as cases involving death, extreme bodily harm, or significant property damage. No new cases may proceed without authorization from the Assistant Attorney General for the Civil Rights Division. The DOJ subsequently dropped three pending FACE Act cases. ⁶

Clinic violence and threats increased significantly in the post-Dobbs period (2022-2024), concurrent with the prosecutions the claim calls “wrongful.” The National Abortion Federation documented: 777 incidents of clinic obstruction in 2023-2024; 296 death threats; 621 incidents of trespassing; 169 acts of vandalism; 38 incidents of assault and battery; 37 incidents of stalking; 3 arsons; and 128,570 protesters picketing clinics. Bomb threats increased 133% from 2021 to 2022 (3 to 7). Death threats rose from 182 in 2021 to 218 in 2022. These numbers represent underreporting due to provider burnout. ⁷

Strong Inferences

The Biden DOJ’s enforcement of the FACE Act was genuinely lopsided, but the remedy of blanket pardons does not follow from the diagnosis. The disparity between 50 pro-life prosecutions and 2 pregnancy center prosecutions — amid over 200 documented attacks on such centers — suggests the Biden DOJ applied the statute asymmetrically. Republicans in Congress documented this disparity in hearings. However, prosecutorial discretion in one direction does not render the other direction’s prosecutions illegitimate. The pardoned individuals were convicted by juries and judges who heard the evidence. Their conduct — forcible entry, physical obstruction, conspiracy to deprive patients of civil rights — met the statutory elements of the offenses. Uneven enforcement is a problem of the unprosecuted cases, not evidence that the prosecuted cases were wrong. ⁸

The addition of conspiracy against rights charges (18 U.S.C. Section 241) elevated what might have been misdemeanor FACE Act violations into felonies with dramatically longer sentences. Section 241 was originally enacted in 1870 to combat Ku Klux Klan violence against Black voters. Applied to FACE Act violations, it converts potential misdemeanor obstruction (six months maximum) into felony conspiracy (up to ten years). This charging strategy produced the sentences that generated public sympathy — 57 months for Handy, 41 months for Williams, combined 23 years for the D.C. defendants. Whether this represents appropriate use of a civil rights statute or prosecutorial overreach is a genuine legal debate, distinct from whether the underlying conduct was criminal. ⁹

The pardons and the subsequent FACE Act enforcement memo together signal that clinic obstruction will face no federal consequences going forward. Pardoning the convicted while simultaneously directing prosecutors not to bring new cases unless “extraordinary circumstances” exist creates a permissive environment for exactly the conduct the FACE Act was designed to prevent. Clinic providers reported that previously convicted activists publicly announced plans to resume and escalate blockade activities following the pardons. The Axios report from February 2025 documented clinics bracing for “reinvigorated protests.” ¹⁰

Informed Speculation

The timing of the pardons — the eve of the March for Life rally — suggests the primary audience was the anti-abortion movement rather than the legal system. Issuing pardons on the basis that prosecutions were “wrongful” while simultaneously moving to suspend the statute under which the prosecutions occurred signals that the objection is not to how the law was applied but to the law’s existence. If the prosecutions were truly anomalous, the remedy would be to enforce the FACE Act even-handedly, not to pardon the convicted and then functionally repeal enforcement.

What the Evidence Shows

The pardons are real, the pardoned individuals are identifiable, and the claim that they were “pro-life Americans” is accurate in the sense that they were motivated by anti-abortion beliefs. In these narrow respects, the claim is factually grounded.

But “wrongly targeted” does an enormous amount of work in this sentence, and the evidence does not support it. The 23 individuals were not prosecuted for their beliefs or for peaceful protest. They were prosecuted for documented physical acts: using deception to enter medical facilities, chaining doors shut, pushing staff members, injuring a nurse, blocking patients in medical emergencies from reaching care, and conspiring to deprive patients of their federal right to access reproductive healthcare. These convictions were obtained through jury trials and bench trials before federal judges, with full due process protections. The conduct met the elements of the charged offenses.

The strongest version of the “wrongly targeted” argument rests not on the individual cases but on the enforcement pattern. The Biden DOJ pursued FACE Act cases against pro-life activists with unprecedented vigor while largely ignoring over 200 attacks on pregnancy centers and churches that the same statute could have addressed. This disparity is real and documented. But selective enforcement of a law does not make properly prosecuted cases invalid — it makes the unprosecuted cases a failure of equal protection. The remedy for that failure would be to prosecute the pregnancy center attackers, not to pardon the clinic invaders.

The pardons are better understood as a political signal than a legal correction. Issued on the eve of the March for Life, accompanied by a DOJ memo functionally suspending FACE Act enforcement, and followed by pardoned activists publicly pledging to resume clinic invasions, the package communicates that anti-abortion activism — including conduct that injures staff and blocks patients from medical care — will face no federal consequences under this administration. For an administration that simultaneously prosecuted over 1,600 January 6 defendants and commuted none, the selective mercy is striking.

The Bottom Line

The pardons happened. The characterization of them as correcting wrongful targeting is misleading. The 23 individuals were convicted of specific criminal acts — not for their beliefs — through ordinary judicial proceedings with full due process. The Biden DOJ’s one-sided enforcement of the FACE Act is a legitimate grievance, but it does not transform forcible clinic invasions, physical assaults on staff, and conspiracy against patients’ civil rights into wrongful prosecution. The claim asks the reader to see political prisoners where the trial records show convicted criminals whose conduct was documented on their own livestreams. Verdict: true that pardons occurred, misleading about why the prosecutions happened and what the pardoned individuals actually did.

Footnotes

1. DOJ Office of the Pardon Attorney, “Clemency Grants by President Donald J. Trump (2025-Present),” https://www.justice.gov/pardon/clemency-grants-president-donald-j-trump-2025-present; NBC News, January 23, 2025; Thomas More Society press release, January 23, 2025. ↩

2. PolitiFact, “Activist Sentenced for Blocking Access to DC Abortion Clinic,” May 17, 2024; Washington Examiner, “Activists who blocked DC abortion clinic get combined 23 years in prison,” May 2024; Ms. Magazine, January 23, 2025. ↩

3. 18 U.S.C. Section 248; Congress.gov, S.636 - Freedom of Access to Clinic Entrances Act of 1994; DOJ Civil Rights Division, “Freedom of Access to Clinic Entrances & Places of Religious Worship.” ↩

4. Ms. Magazine, January 23, 2025; PolitiFact, May 17, 2024; Catholic News Agency, “89-Year-Old Death Camp Survivor Convicted,” 2024; Politifact, “Bevelyn Beatty Williams sentenced to 41 months,” October 2024. ↩

5. Washington Examiner, “Abortion opponents see sharp rise in FACE Act charges under Biden administration,” 2024; Washington Stand, “436 Church Attacks in 2023, Zero Prosecutions under the FACE Act,” 2024; House Judiciary Committee hearing, December 2024. ↩

6. CBS News, “Trump Justice Dept. limits enforcement of FACE Act,” 2025; NPR, “DOJ limits enforcement of FACE Act, fueling concerns among abortion providers,” March 9, 2025. ↩

7. National Abortion Federation 2024 Violence & Disruption Statistics; CNN, “Abortion clinics saw an increase in violence and threats in 2022,” 2023; Axios, “Abortion clinics brace for reinvigorated protests,” February 5, 2025. ↩

8. Washington Examiner, 2024; House Judiciary Committee hearing, December 2024; individual trial records and sentencing transcripts. ↩

9. 18 U.S.C. Section 241; Lawfare, “Three Questions About Section 241”; sentencing records for Handy (57 months), Williams (41 months), and D.C. co-defendants. ↩

10. CBS News, 2025; NPR, March 2025; Axios, February 2025. ↩