Judge Permanently Blocks Release of Jack Smith's Volume II Report
Judge Aileen Cannon on Feb. 23 barred DOJ from releasing former special counsel Jack Smith's report on the Mar-a-Lago classified documents probe.
Overview
On Feb. 23, U.S. District Judge Aileen Cannon permanently barred the Justice Department from releasing Volume II of Special Counsel Jack Smith's report on the classified documents investigation.
Cannon wrote releasing the report would be a 'manifest injustice' because Smith acted 'without lawful authority' and she had dismissed the indictment in July 2024.
President Donald Trump and co-defendants Walt Nauta and Carlos de Oliveira sought Cannon's order to block the report, and the Justice Department told the court Smith's investigation was unlawful from its inception.
The ruling shields from public view evidence gathered in one of four criminal cases against Trump, and Volume I of Smith's report was released by the Justice Department before Trump took office in January 2025.
Cannon's order bars Justice Department officials, including successors, from sharing Volume II and is likely to prompt appeals by public transparency groups testing access to the report.
Analysis
Center-leaning sources portray the ruling as part of a pattern of judicial decisions shielding Trump, using emphasis on Cannon's prior dismissals and the ruling's effect on public access to evidence. Editorial choices—phrases like "protect Trump" and highlighting "manifest injustice"—frame a critical narrative, while direct court quotes remain source content.
Sources (17)
FAQ
Volume II details the investigation into President Trump's alleged mishandling of sensitive government documents at Mar-a-Lago and alleged obstruction of the federal probe.
Judge Cannon ruled that releasing it would cause a 'manifest injustice' since Smith acted without lawful authority, the case was dismissed, and defendants retain presumption of innocence; it also contains protected discovery materials.
President Donald Trump and co-defendants Walt Nauta and Carlos de Oliveira sought the order; the Justice Department also opposed release after Trump took office.
Transparency groups like American Oversight and Knight First Amendment Institute were denied intervention; their appeals are pending at the 11th Circuit Court of Appeals.
Yes, Volume I, addressing Trump's 2020 election interference, was released by the Justice Department in January 2025 before Trump took office.
History
9 sources