U.S. District Judge Aileen Cannon on Monday permanently barred the Justice Department from releasing Volume II of former special counsel Jack Smith’s final report on President Donald Trump’s handling of classified documents at Mar-a-Lago and alleged obstruction tied to efforts to retrieve them.
In a 15-page order, Cannon said releasing the report outside the department would violate both her earlier dismissal ruling in the case and a protective order governing discovery. She also pointed to unresolved concerns involving grand jury secrecy and attorney-client privilege, and warned that public dissemination would be fundamentally unfair because there was no adjudication of guilt.
“Special Counsel Smith and his team went ahead for months, undeterred,” Cannon wrote in the ruling, saying the work on the report continued after her court had dismissed the prosecution. The order said that chronology reflected “a concerning breach of the spirit of the Dismissal Order,” and potentially an outright violation.
Cannon’s decision enjoins Attorney General Pam Bondi, the Justice Department, and department personnel from releasing, sharing, transmitting, or otherwise conveying Volume II — or any drafts — outside DOJ. The prohibition also extends to sharing “any information or conclusions” contained in the report with anyone outside the department.
The order traces the dispute back to Cannon’s July 15, 2024, dismissal of the superseding indictment against Trump and two co-defendants, Waltine Nauta and Carlos De Oliveira. Cannon concluded Smith’s appointment violated the Constitution’s Appointments Clause and said actions flowing from that appointment in the case were invalid. Smith appealed but did not seek a stay, and the appeal was later dropped.
Cannon had previously blocked release of the report in January 2025 amid concerns it contained discovery material covered by a Rule 16 protective order. A later order set a Feb. 24, 2026, expiration for that restriction, prompting the defendants’ motions that led to Monday’s permanent bar.
The ruling is laid out in the court filing, U.S. District Court order, entered Feb. 23, 2026.
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