In Elementary, Dear Data, Picard promised not to delete Moriarty's program from the holodeck and said they may revisit him at some point. Well by the time Voyager came and went, the technology was available to free him from the holodeck. So do you think Starfleet, having been briefed on the situation, ever freed him? I'd think not, but Picard may have felt some moral need to think about doing so.