Judge Cannon Permanently Bars Release of Jack Smith’s Trump Classified‑Documents Report
Judge Aileen Cannon entered a permanent order barring the Justice Department from releasing, distributing, or sharing any information or conclusions in Volume II (and its drafts) of Special Counsel Jack Smith’s two‑volume report on the Mar‑a‑Lago classified‑documents probe, saying disclosure would cause a "manifest injustice" to Trump and his co‑defendants after she dismissed the indictment. Cannon also questioned Smith’s authority, rejected a defense request to destroy the report, and left ongoing litigation over public access as outside groups press appeals while DOJ — which had briefly appealed Cannon’s 2024 dismissal but abandoned that appeal after Trump’s 2024 election under the department’s policy against indicting a sitting president — agreed Volume II should not be released.
📌 Key Facts
- Judge Aileen Cannon entered a permanent order barring public release of Special Counsel Jack Smith’s report on Trump’s handling of classified documents (Volume II) and explicitly prohibited the DOJ from "releasing, distributing, conveying, or sharing" any information or conclusions in Volume II or its drafts with anyone outside the department.
- Cannon said releasing Volume II would cause "manifest injustice" to Trump and his co‑defendants because the indictment was dismissed and they "still enjoy the presumption of innocence," and she tied that reasoning to her view that Smith acted without lawful authority/was unconstitutionally appointed.
- Smith prepared a two‑volume report covering both the Mar‑a‑Lago classified‑documents case (Volume II) and Trump’s efforts to overturn the 2020 election; prosecutors dropped both prosecutions after Trump’s 2024 election win under DOJ policy against indicting a sitting president.
- The DOJ had appealed Cannon’s 2024 dismissal of the classified‑documents case but abandoned that appeal after Trump won the presidency.
- Cannon rejected a separate defense request to order destruction of the report itself, even while blocking its disclosure.
- Outside groups are pressing for release of the report in a pending appeal, signaling ongoing litigation over public access despite the DOJ’s agreement that Volume II should not be released.
- Cannon distinguished this situation from prior special‑counsel reports (e.g., Mueller), saying those public reports followed declinations or findings of guilt, whereas here contested charges were dismissed before trial.
- Supporters characterized the injunction as a significant victory for Trump and his co‑defendants in the classified‑documents case.
📰 Source Timeline (4)
Follow how coverage of this story developed over time
February 23, 2026
3:20 PM
Judge permanently blocks release of special counsel Jack Smith's report on Trump classified documents case
New information:
- Confirms Cannon has entered a permanent order barring public release of Jack Smith’s report on Trump’s hoarding of classified documents at Mar‑a‑Lago, at Trump’s request.
- Details Cannon’s rationale that releasing the report would be a 'manifest injustice' to Trump and his co‑defendants because the indictment was dismissed and they 'still enjoy the presumption of innocence.'
- Clarifies that Smith prepared a two‑volume report covering both the Mar‑a‑Lago documents case and Trump’s efforts to overturn the 2020 election, with both prosecutions dropped after Trump’s 2024 election win under DOJ policy against indicting a sitting president.
- Cannon distinguishes this situation from past special counsel reports (e.g., Mueller) by stressing that prior public reports followed either declinations or findings of guilt, not contested charges dismissed before trial.
2:45 PM
Federal judge blocks release of Jack Smith report's second volume
New information:
- Confirms Cannon’s Monday order explicitly prohibits DOJ from 'releasing, distributing, conveying, or sharing' any information or conclusions in Volume II or its drafts with anyone outside DOJ.
- Frames the order as a 'significant victory' for Trump and his co‑defendants in the classified‑documents case.
- Reiterates Cannon’s earlier view that Jack Smith was unconstitutionally appointed, tying this new injunction to her broader posture toward his probe.
2:39 PM
Judge Cannon blocks release of Jack Smith’s classified documents report
New information:
- The article quotes Cannon’s opinion that releasing Volume II would cause 'manifest injustice to the former defendants' and that Special Counsel Jack Smith 'acted without lawful authority' in obtaining Trump’s indictment.
- It recaps that DOJ had appealed Cannon’s 2024 dismissal of the classified‑documents case but abandoned the appeal after Trump won the presidency, citing the department’s policy against prosecuting a sitting president.
- It notes Cannon rejected a separate Trump defense request to order the destruction of the report itself, even while blocking its disclosure.
- The piece highlights that outside groups are pressing for release of the report in a pending appeal, signaling ongoing litigation over public access despite DOJ’s agreement that Volume II should not be released.