A federal judge on Monday permanently blocked the release of the second volume of former special counsel Jack Smith’s report, a decision that marks a significant legal and political victory for President Donald Trump and his co-defendants. The volume in question centers on Trump’s handling of classified documents after leaving office at the end of his first term. The ruling ensures that the Justice Department cannot make public the findings, conclusions, or related materials contained in Volume II, even as debate continues over the broader implications of Smith’s investigation. The decision came just one day before the report had been scheduled for release, intensifying attention around the case and underscoring the ongoing clash between the former special counsel’s office and Trump’s legal team.

U.S. District Judge Aileen Cannon, who was appointed to the federal bench by Trump, sided with the president’s request to permanently bar publication of the report’s second volume. In a 15-page order, Cannon wrote that releasing the document would constitute a “manifest injustice” to Trump and the other defendants named in the classified documents case. She emphasized that Special Counsel Smith had acted “without lawful authority” in obtaining an indictment and initiating proceedings that ultimately ended in dismissal of all charges. According to Cannon, allowing the report’s release after the dismissal would undermine fundamental principles of fairness, particularly given that the defendants have consistently maintained their innocence and were not convicted at trial.

The judge’s order specifically prohibits the Justice Department from “releasing, distributing, conveying, or sharing with anyone outside the Department of Justice any information or conclusions in Volume II or in drafts thereof.” The sweeping language of the injunction reflects the court’s concern that public dissemination could reveal sensitive or privileged material. Cannon noted that while previous special counsels have released final reports, those circumstances typically involved either decisions not to bring charges or cases that ended in convictions through plea agreements or trials. She wrote that the court could not identify a comparable situation in which a former special counsel released a report after filing charges that were contested from the outset and ultimately dismissed without a finding of guilt.

The underlying investigation began in 2022, when then–Attorney General Merrick Garland appointed Smith to examine two major matters involving Trump. One focused on alleged efforts to challenge the results of the 2020 presidential election, and the other concerned Trump’s retention of classified materials at his Mar-a-Lago residence in Palm Beach, Florida, after leaving office in January 2021. In the classified documents case, Smith’s team alleged that Trump kept highly sensitive records and obstructed government attempts to retrieve them. Trump pleaded not guilty and repeatedly argued that the prosecution was politically motivated. The charges were later dropped following Trump’s re-election in 2024, consistent with longstanding Justice Department policy that a sitting president should not face federal criminal prosecution.

Cannon had previously ruled that Smith’s appointment as special counsel was unlawful, a conclusion that added another layer of controversy to the proceedings. After Trump’s 2024 victory and the dismissal of the charges, Smith stepped down from his position. Supporters of the president hailed the permanent block on Volume II as a vindication. Trump’s former defense attorney, Kendra Wharton, praised Cannon’s “courage and judicial resolve,” saying her stance on due process should be studied in law schools across the country. Critics, however, argue that preventing the report’s release shields important information from public scrutiny, especially given the national security issues tied to classified materials.

For his part, Smith has consistently rejected accusations that his investigation was driven by politics. In both public remarks and private testimony before members of Congress, he defended the integrity of his team’s work. He stated that investigators uncovered “powerful evidence” that Trump retained highly classified documents and obstructed efforts to recover them. Smith has maintained that his decisions were made without regard to Trump’s political affiliation, campaign activities, or candidacy in the 2024 election. Despite those assertions, the court’s order now ensures that the second volume of his report will remain confidential outside the Justice Department, at least for the foreseeable future, leaving unresolved questions about transparency, executive power, and the balance between due process and the public’s right to know.