Florida judge blocks release of Jack Smith’s report on Mar-a-Lago docs case against Trump

US District Court of the Southern District of Florida, West Palm Beach Division Judge Aileen Cannon previously dismissed in July 2024 the charges against Trump after ruling that Smith had been unlawfully appointed as special counsel. While Smith had appealed the decision, the case ultimately came to an end with Trump’s 2024 victory. The Monday order blocks Attorney General Pam Bondi and her successors from releasing, sharing, or transmitting the second volume of Smith’s report.

Cannon granted Trump’s request to block the release of the second volume of Smith’s report on the case. She wrote, "All parties agree that authorizing public release of Volume II would contravene the conclusions in the Court’s final Dismissal Order that Special Counsel Smith acted without lawful appointment or funding authority in this proceeding and that his actions taken in connection therewith are therefore invalid."

She wrote that release of the second volume outside of the Department of Justice "would plainly offend the Court’s Dismissal Order and the Rule 16 Protective Order, both of which remain in force; it would cause irreparable damage to former defendants from disclosure of non-public discovery material implicating still-contested grand jury and privilege concerns; and it would contravene basic notions of fairness and justice in the process, where no adjudication of guilt has been reached following initiation of criminal charges."

She later added, "Moreover, while it is true that former special counsels have released final reports at the conclusion of their work, it appears they have done so either after electing not to bring charges at all or after adjudications of guilt by plea or trial. The Court strains to find a situation in which a former special counsel has released a report after initiating criminal charges that did not result in a finding of guilt, at least not in a situation like this one, where the defendants contested the charges from the outset and still proclaim their innocence."

Per CBS News, the report was set to become public on Tuesday without Cannon’s order. The first volume of Smith’s report was released in early 2025 and related to the 2020 election case against Trump.