U.S. District Judge Aileen Cannon blocked the release of the second volume of former special counsel Jack Smith's report on President Donald Trump's handling of classified materials, granting Trump's request just one day before the report was scheduled to go public on Tuesday.
Cannon's order goes further than a temporary hold. It prohibits U.S. Attorney General Pam Bondi or her successors from releasing those specific documents, effectively sealing the volume from public view. The judge said releasing the report would have represented a "manifest injustice."
According to Breitbart, Bondi had already determined independently that the report's second volume shouldn't be released to the public, in part because of unresolved questions surrounding the legality of Smith's appointment as special counsel. Cannon's ruling formalizes what the Attorney General had already concluded.
The timeline of Smith's tenure tells its own story. In 2022, Smith was chosen to probe allegations that Trump and his allies tried to overturn the 2020 election and to investigate his handling of alleged classified documents at his Florida home in 2021. He brought charges against Trump. Cannon, who oversaw the prosecution in the documents case, ruled in July 2024 that Smith was unlawfully appointed special counsel and dismissed the charges against the president.
Then Trump was elected in 2024. The remaining charges were dropped. Smith resigned not long afterwards.
The whole affair followed a now-familiar pattern: an aggressive, arguably illegitimate prosecution that collapses under legal scrutiny and political reality. The fact that a federal judge found Smith's very appointment unlawful is not a footnote. It is the headline. Everything that flowed from that appointment carries the same taint.
Smith testified before the House Judiciary Committee in January, and by Trump's account, the appearance did not go well for the former special counsel. Trump said Smith was getting "decimated" during his testimony:
"It was over when they discussed his past failures and unfair prosecutions. He destroyed many lives under the guise of legitimacy."
Trump did not mince words about his view of Smith's conduct overall:
"Jack Smith is a deranged animal, who shouldn't be allowed to practice Law. If he were a Republican, his license would be taken away from him, and far worse!"
Strong language, but consider the context. This is a man who was subjected to a yearslong investigation by a prosecutor whose appointment was ruled unlawful by a federal court. The prosecution ended not with a conviction but with a dismissal and a resignation.
The questions about Smith's conduct extend beyond the Trump cases themselves. In October 2025, it was revealed that Smith had tracked phone records of Republican members of Congress in his "Arctic Frost" investigation. That detail alone deserves sustained congressional attention. A special counsel, later found to have been unlawfully appointed, was surveilling the communications of elected legislators.
This is not the behavior of a dispassionate prosecutor following the evidence. It is the behavior of an office that operated with minimal accountability and maximal reach, targeting political opponents of the administration that appointed it.
The left will frame Cannon's ruling as a cover-up, as Trump hiding something. That framing requires ignoring several inconvenient facts:
A special counsel report from a lawfully appointed prosecutor, following a completed investigation that resulted in actual legal proceedings, might have a legitimate claim to public release. That is not what happened here. Smith's office was built on a flawed legal foundation, pursued charges that never reached a jury, and the man behind it resigned and walked away. Releasing his parting memo would give unearned credibility to a process that a federal court already invalidated.
Every major legal effort to derail Trump has followed the same arc: breathless media coverage at launch, procedural aggression in the middle, and quiet collapse at the end. What never comes is accountability for the prosecutors and officials who pushed these efforts forward. Smith resigned. He testified before Congress. He tracked the phone records of sitting lawmakers. And now his final report sits behind a court order, blocked not by executive fiat but by a federal judge who found that releasing it would be unjust.
Cannon's ruling doesn't hide the truth. It recognizes that a document produced by an unlawfully appointed prosecutor, summarizing a case that was never tried, is not truth. It is argument without cross-examination.
The second volume stays sealed. The prosecution stays dismissed. And Jack Smith stays retired.