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A federal judge on Monday agreed to permanently block the release of volume two of former special counsel Jack Smith's report — centered on President Donald Trump's handling of classified materials after his first term in office — in a significant victory for the president and his co-defendants.
U.S. District Judge Aileen Cannon, a Trump appointee, granted the president's request to permanently block the release of the second volume of the report, ruling that its publication would represent a "manifest injustice" both to Trump and the co-defendants in the classified documents case.
"Special Counsel Smith, acting without lawful authority, obtained an indictment in this action and initiated proceedings that resulted in a final order of dismissal of all charges," Cannon said Monday.
JACK SMITH SUBPOENAED FOR DEPOSITION WITH HOUSE JUDICIARY COMMITTEE
Former special counsel Jack Smith says the Pledge of Allegiance before he testifies before the House Judiciary Committee on Capitol Hill on Jan. 22, 2026, in Washington, D.C. (Al Drago/Getty Images)
The ruling blocks the Justice Department from "releasing, distributing, conveying, or sharing with anyone outside the Department of Justice any information or conclusions in Volume II or in drafts thereof."
Cannon previously ruled that Smith was unconstitutionally appointed as special counsel, though the matter was ultimately dismissed following Trump's re-election in 2024.
Smith was tapped by former Attorney General Merrick Garland in 2022 to investigate the alleged effort by Trump and his allies to overturn the results of the 2020 election, as well as Trump's retention of allegedly classified documents at his Mar-a-Lago residence in Palm Beach after leaving office in 2021.
Smith had brought charges against Trump in both cases.
The charges were dropped after Trump's election, in keeping with a long-standing Justice Department policy that discourages prosecuting sitting presidents on federal criminal charges. Smith resigned from his role shortly afterward.
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Breanne Deppisch is a national politics reporter for Fox News Digital covering the Trump administration, with a focus on the Justice Department, FBI and other national news. She previously covered national politics at the Washington Examiner and The Washington Post, with additional bylines in Politico Magazine, the Colorado Gazette and others. You can send tips to Breanne at [email protected], or follow her on X at @breanne_dep.
