On January 5, 2015, Sirhan was denied freedom by U.S. District Judge Beverly Reid O'Connell in Los Angeles, who said that Sirhan "failed to meet the showing required for actual innocence" that might excuse his having failed to seek his freedom sooner in federal court.
The next day, on June 6, the Los Angeles Times printed an article by Jerry Cohen which discussed Sirhan's motive for the assassination, confirmed by the memos that Sirhan wrote to himself.