Judge Cannon Permanently Blocks Release of Jack Smith's Report on Trump's Classified Documents

U.S. District Judge Aileen Cannon on February 23, 2026 permanently barred the Justice Department from releasing Volume II of former special counsel Jack Smith's final report, which covers the investigation into Trump's retention of classified documents. The order binds Attorney General Pam Bondi and her successors. Cannon wrote that the remaining defendants still enjoy the presumption of innocence and that the report draws on voluminous discovery subject to protective orders, and said it would be unprecedented for a former special counsel's report to be released after charges that did not result in a finding of guilt. Cannon had dismissed the charges in July 2024 on the ground that Smith's appointment was unlawful; Volume I of the report became public before Trump's second inauguration, while Volume II remained sealed.

The ruling closes off public access to the record of a criminal investigation of a sitting president, decided by the judge who dismissed that prosecution. The competing interests are defendants' fair-trial protections and the public's interest in the factual record assembled by a special counsel.

American Oversight and the Knight First Amendment Institute, which sought release, appealed. A federal appeals court allowed the watchdog groups to challenge Cannon's order.