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Reading: Federal Judge Blocks Release of Jack Smith Report Volume Two
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Baner Club > Blog > News > Federal Judge Blocks Release of Jack Smith Report Volume Two
NewsUnited States

Federal Judge Blocks Release of Jack Smith Report Volume Two

Last updated: 2026/02/23 at 7:15 PM
Published February 23, 2026
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Judge Aileen Cannon issues ruling blocking Jack Smith report Volume II
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Judge Aileen Cannon halts publication of second report

A federal judge has permanently blocked the release of the second volume of former special counsel Jack Smith’s report. This report investigated President Donald Trump’s handling of classified materials after his first term. The ruling is a significant victory for Trump and his co-defendants.

Contents
Judge Aileen Cannon halts publication of second reportLegal reasoning and contextBackground of the investigationReactions

U.S. District Judge Aileen Cannon, appointed by Trump, said publishing Volume II would cause a “manifest injustice.” Consequently, the Justice Department cannot share any part of the report outside the department.

Legal reasoning and context

Cannon noted that releasing the report could violate fairness and attorney-client privilege. She highlighted that special counsels usually release final reports only after no charges or after convictions. She stressed that situations like this—where defendants disputed charges and claim innocence—are extremely rare.

“Allowing release here would contravene basic notions of justice,” Cannon wrote in her 15-page order. She added that prior special counsels have not released reports after charges that did not lead to a conviction.

Background of the investigation

Smith was appointed in 2022 by former Attorney General Merrick Garland. He was tasked with investigating Trump’s attempts to overturn the 2020 election and his retention of classified documents at Mar-a-Lago. Smith brought charges in both cases, which were later dropped after Trump’s 2024 re-election, following Justice Department policy. Smith then resigned.

Smith’s team said they had strong evidence that Trump retained classified records and obstructed government efforts to retrieve them. Meanwhile, Trump’s former attorney Kendra Wharton praised Cannon’s ruling. She called it a demonstration of “courage and judicial resolve” on due process issues.

Reactions

Neither Smith’s law firm nor the Justice Department immediately commented. Cannon had previously questioned the constitutionality of Smith’s appointment, though the matter was dismissed.

Wharton also noted the decision reinforces critical legal principles. She said the ruling should be studied in law schools as an example of protecting due process. Smith, meanwhile, defended his team and denied political bias.

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TAGGED: Aileen Cannon, Baner Club, Classified Documents Case, Donald Trump, Jack Smith

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