A federal judge has permanently barred the release of Special Counsel Jack Smith's report on his investigation into President Donald Trump's handling of classified documents at his Mar-a-Lago estate.
In a ruling on Monday, US District Judge Aileen Cannon found that making the report public would amount to a “manifest injustice” to Trump and his two former co-defendants in a criminal case that never reached trial.
The order prevents the Justice Department from disclosing substantial details about one of the four criminal cases Trump faced during the years between his first and second terms in office.
What The Court Said
Cannon, who was nominated to the federal bench by Trump in 2020, had previously dismissed the classified documents case in 2024, concluding that Smith had been unlawfully appointed.
In Monday's order, she wrote: “Special Counsel Smith, acting without lawful authority, obtained an indictment in this action and initiated proceedings that resulted in a final order of dismissal of all charges.”
“As a result, the former defendants in this case, like any other defendant in this situation, still enjoy the presumption of innocence held sacrosanct in our constitutional order,” she further added.
Cannon noted that while special counsels have historically released reports at the conclusion of their work, those disclosures typically occurred either after declining to bring charges or after a conviction.
“The Court strains to find 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,” she wrote, particularly in a case “where the defendants contested the charges from the outset and still proclaim their innocence.”
She further said disclosure of the report “would contravene basic notions of fairness and justice in the process, where no adjudication of guilt has been reached.”
The Case Against Trump
The now-dismissed case accused Trump of unlawfully retaining classified national defence documents — including materials related to the US nuclear programme — at his Mar-a-Lago residence in Florida after leaving the White House following his first term.
Smith's team alleged that Trump had obstructed government efforts to retrieve the documents. Trump and his co-defendants — personal aide Walt Nauta and Mar-a-Lago manager Carlos de Oliveira — pleaded not guilty and argued the case was politically motivated.
Cannon dismissed all charges in 2024 after finding that Smith's appointment by the Justice Department during the administration of former President Joe Biden was unlawful.
Why The Charges Were Abandoned
Smith had produced a two-volume report covering Trump's alleged efforts to overturn the 2020 election results and the classified documents investigation.
Both cases had resulted in indictments. However, after Trump won the November 2024 presidential election, Smith's team abandoned the prosecutions in line with longstanding Justice Department opinions that sitting presidents cannot face federal prosecution.
The Justice Department under Trump supported the move to block the report's release, arguing it was a confidential internal document. Earlier, the Biden-era DOJ had dropped attempts to revive the case after Trump's electoral victory.
Cannon also cited concerns about the disclosure of confidential grand jury material and concluded that Smith's drafting of the report circumvented her earlier ruling that he was unlawfully appointed.
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