Judge blocks release of Jack Smith’s report on Trump documents case

A federal judge appointed by Donald Trump permanently barred the justice department on Monday from releasing the former special counsel Jack Smith’s report on the president’s mishandling of classified documents at his Mar-a-Lago club after his first term.

The ruling by US district judge Aileen Cannon marked the latest effort to stop the report from being sent to Congress or otherwise becoming publicly available.

In scathing language, Cannon condemned Smith for what she called a “brazen stratagem” of compiling a report even after she had dismissed the case on grounds that he was unlawfully appointed, a decision that flew in the face of historical precedent.

“To say this chronology represents, at a minimum, a concerning breach of spirit of the dismissal order is an understatement, if not an outright violation of it,” she wrote in her 15-page decision.

Cannon also ruled that releasing the report into the classified documents case, known as volume II after the first volume addressed Trump’s efforts to overturn the 2020 election, would release secret grand jury material that could cause irreparable harm to the president.

In doing so, she endorsed the view proffered by Trump’s personal lawyers – one of whom, Todd Blanche, now serves as the US deputy attorney general – that the report should never see the light of day because the prosecutor who wrote it should never have been appointed.

Cannon conceded that previous special counsels have written reports on their work that have been later publicly released by the justice department, as Robert Mueller did with his report on the 2016 Trump campaign’s ties to Russia and efforts to obstruct that inquiry.

But she blocked Smith from doing the same, claiming the circumstances of the case – in which Trump was charged but never brought to trial – meant it was not fair for Trump to have details of the case made public.

Volume II of Smith’s report is understood to contain details about Trump’s efforts to retain highly classified documents at his Mar-a-Lago club, as well as his subsequent efforts to obstruct the government’s attempts to retrieve them.

Smith charged two co-defendants in addition to Trump – his valet Walt Nauta and a Mar-a-Lago employee Carlos de Oliveira – for moving boxes of classified documents around the club after Trump received a grand jury subpoena demanding their return.

After Cannon dismissed the classified documents case in 2024, Smith challenged the decision to the US appeals court for the 11th circuit. But following Trump’s re-election, Smith elected to drop the appeal and resigned.

Smith also dropped his election interference prosecution, overseen by a different federal judge in Washington who did not consider him unlawfully appointed, after the 2024 election. The report on that case was made public in January 2025.

Last month, Smith testified to Congress to defend his decision to seek criminal charges against Trump in the election interference case. Barred by the protective order imposed by Cannon, he was unable to discuss the classified documents case during his testimony.