A federal judge has handed President Donald Trump and his codefendants a legal victory by blocking the release of the second volume of former special counsel Jack Smith’s report related to Trump’s handling of classified materials after his first term in office.
Trump-appointed U.S. District Judge Aileen Cannon granted the request to prevent the report’s release, according to an article published Monday by Fox News. The volume had been scheduled for public release on Tuesday, but Cannon ruled that doing so would result in a “manifest injustice” to Trump and others named in the case.
Smith was appointed in 2022 to investigate allegations that Trump and his allies sought to overturn the 2020 election and to examine Trump’s handling of classified documents at his Florida residence in 2021. Although Smith brought charges against Trump, those charges were dropped after Trump’s election victory in 2024, and Smith resigned shortly thereafter.
Cannon’s order bars U.S. Attorney General Pam Bondi and her successors from releasing the second volume of the report. CBS News reported that Bondi had already concluded the volume should not be released, citing concerns over the legality of Smith’s appointment. Cannon previously ruled in July 2024 that Smith had been unlawfully appointed special counsel and dismissed the classified documents case against Trump.
Smith later testified before the House Judiciary Committee in January. Breitbart News reported that in October 2025 it was revealed Smith had tracked phone records of Republican members of Congress during his “Arctic Frost” investigation.
Reacting to Smith’s testimony and past actions, Trump said Smith was being “decimated” and accused him of abusing the legal system. Trump claimed Smith had “destroyed many lives under the guise of legitimacy” and called him unfit to practice law, arguing that similar conduct by a Republican would have resulted in severe consequences.
The ruling effectively ensures that the second volume of Smith’s report will remain sealed, marking another major legal setback for the former special counsel and a political win for Trump.
