expulsion of 10 Russian diplomats, a sanction imposed by the United States against Russia for its SolarWinds hack, aggression against Ukraine, and interference in the 2020 U.S. election. In May 2021, the DOJ appealed in part a ruling by Judge Amy Berman Jackson of the District Court for the District of Columbia to make public most of a DOJ memo detailing former Attorney General Bill Barr's legal rationale for clearing President Trump of obstruction of justice in the Special Counsel investigation. On June 7, 2021, the Justice Department continued its defense of a defamation lawsuit by E. Jean Carroll, arguing that President Trump could not be sued because he had denied her rape allegation in offending statements in his presidential capacity. Garland had been deeply involved in the decision. The White House quickly distanced itself from the decision. Garland in a House Judiciary Committee hearing on October 21 stated that the DOJ's briefing was solely on the question of the application of the Federal Tort Claims Act. On July 1, 2021, Garland imposed a moratorium on all federal executions pending a review of relevant policies and procedures. The review will examine "the risk of pain and suffering associated with the use of pentobarbital," "regulations made in November 2020 that expanded the permissible methods of execution beyond lethal injection, and authorized the use of state facilities and personnel in federal executions", and "December 2020 and January 2021 changes to expedite execution of capital sentences." This was consistent with Biden's pledge to push for legislation to end the federal death penalty. In spite of this, Garland has continued to pursue the death penalty in cases wherein a previous administration had sought the death penalty against a suspected terrorist. The Trump administration resumed federal executions in 2019, and executed 13 inmates in total, the first in 17 years and including the first woman in 70 years. Civil rights During Garland's tenure as AG, the Justice Department has emphasized protection of civil rights. Garland rescinded a Trump administration policy (imposed by Jeff Sessions) that curtailed DOJ investigations into police department misconduct ("pattern-and-practice" investigations) and restricted the use of consent decrees to reform police departments. On April 21, 2021, Garland subsequently announced that the DOJ was opening a pattern-and-practice investigation into the Minneapolis Police Department after former officer Derek Chauvin was convicted for the murder of George Floyd, examining the use of force by officers