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A federal judge has blocked the public release of Special Counsel Jack Smith’s final report detailing his investigation into former President Donald Trump’s handling of classified documents after leaving office. The decision, handed down Monday by U.S. District Judge Aileen Cannon in Florida, represents a significant victory for Trump in his efforts to maintain the special counsel’s findings from public view.
Judge Cannon, who previously dismissed the criminal case brought by Smith before Trump’s reelection, ruled that it is not customary for a prosecutor whose case was dismissed to then publicly disseminate evidence generated during the investigation. The ruling centers on the second volume of Smith’s report, which has remained under seal amid legal challenges from Trump and his co-defendants. The first volume, concerning alleged efforts to overturn the 2020 election, was released prior to Trump’s return to the White House.
Smith initially submitted the two-volume report to then-Attorney General Merrick Garland in early 2025. The ongoing legal battle over the report’s release underscores the intense scrutiny surrounding Trump’s handling of classified materials and the investigations into his conduct both during and after his presidency. The core issue revolves around transparency and the public’s right to access information related to investigations involving a former president.
In her 15-page ruling, Cannon stated, “The Court strains to uncover a situation in which a former special counsel has released a report after initiating criminal charges that did not result in a finding of guilt, at least not in a situation like this one, where the defendants contested the charges from the outset and still proclaim their innocence.” She also criticized Smith for even preparing the report, arguing it violated her earlier rulings that effectively halted his office’s work on the classified documents matter. Politico reported on the judge’s reasoning, highlighting her concerns about the unusual nature of releasing a report after a case dismissal.
Cannon’s Previous Rulings and Concerns Over Impartiality
This decision follows a pattern of rulings by Judge Cannon that have been favorable to Trump throughout the investigation. In 2024, she concluded that Smith was unlawfully serving as special counsel, a decision that raised questions about her impartiality. Critics have argued that Cannon’s rulings demonstrate a bias in favor of the former president. MSNBC detailed the history of Cannon’s rulings in the case, noting the ongoing appellate reviews of her actions.
Cannon declined a request from two of Trump’s former co-defendants to order the complete destruction of the report. However, her decision to block its release is likely to fuel further legal challenges and public debate.
Appeals and Transparency Efforts Continue
Despite Cannon’s ruling, the fight for transparency surrounding Smith’s report is far from over. Appeals have been filed by public transparency groups seeking to compel the release of Volume II of the report. The Knight First Amendment Institute at Columbia University, for example, has actively pursued the release of the report, arguing that the public has a right to access it under the First Amendment and the Freedom of Information Act. The Knight Institute asked the U.S. Court of Appeals for the Eleventh Circuit to reverse Cannon’s order.
American Oversight has also appealed Judge Cannon’s order, arguing it could clear the way for Trump to permanently destroy the report. American Oversight filed an expedited motion to prevent Cannon from granting Trump’s requests to keep the public in the dark regarding the report’s preservation.
What’s Next in the Case
The Eleventh Circuit Court of Appeals will now review Judge Cannon’s decision. The outcome of that review will determine whether the public will ever have access to the full scope of Smith’s findings regarding Trump’s handling of classified documents. The case continues to highlight the complex legal and political challenges surrounding investigations into former presidents and the balance between executive privilege, transparency, and accountability. The appellate court’s decision is expected to be a key moment in determining the future of this case and the public’s understanding of the investigation.
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