Judge Aileen Cannon has permanently blocked the release of Volume II of special counsel Jack Smith’s report on President Trump’s handling of classified materials, granting Trump’s request and forbidding the Department of Justice from sharing the report’s contents outside the agency.

The order, issued Monday, runs 15 pages and explicitly bars the Department of Justice from “releasing, distributing, conveying, or sharing with anyone outside the Department of Justice any information or conclusions in Volume II or in drafts thereof.” That injunction arrived just before a planned public release and stops the report in its tracks. The ruling is framed around fairness and the limits of prosecutorial reach when charges do not result in conviction.

Cannon’s decision zeroes in on the basic problem of a prosecutor getting the last word when the courtroom did not deliver a verdict. She found that 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.” Releasing a post-dismissal report, the judge said, would amount to “manifest injustice” and would “contravene basic notions of fairness and justice.”

“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.”

That distinction matters because a report published after a conviction simply collects the public record, while a report published after dismissal is effectively a prosecutor trying to sway public opinion without a jury. This is not a technicality; it changes who gets to decide guilt in our system. Cannon emphasized that precedent for a post-indictment public report that follows a dismissal is essentially nonexistent.

Jack Smith was named by Attorney General Merrick Garland in 2022 to lead investigations into two major subjects: alleged efforts to overturn the 2020 election and the retention of classified documents at Mar-a-Lago after President Trump left office. Smith pursued charges in both matters, but the classified documents case was dismissed after President Trump’s 2024 re-election, consistent with a long-standing Justice Department policy that discourages prosecuting sitting presidents on federal criminal charges. Smith resigned from his special counsel role soon after those decisions.

None of the cases produced a guilty plea or a conviction. Despite that outcome, Smith moved to publish a second volume describing what he called “powerful evidence,” seeking to present his theory of the case directly to the public. He also defended his team’s choices in interviews and appearances with House Republicans, insisting on the impartiality of his decision-making.

“I made my decisions in the investigation without regard to President Trump’s political association, activities, beliefs or candidacy in the 2024 presidential election.”

The insistence on publishing a dossier after all charges were dismissed struck many as an attempt to achieve a prosecution-by-press-release. If the evidence was truly as decisive as described, it should have survived the adversarial process in court. The judge’s order prevents a prosecutor from bypassing the verdict with a public brief meant to substitute for a jury’s work.

Defenders of the ruling say this is a straightforward protection of due process rather than a political maneuver. Trump’s former defense attorney Kendra Wharton praised Cannon’s decision, saying Cannon’s “courage and judicial resolve on these important due process issues should be recognized and taught in law school classrooms across America.” That view treats the order as a defense of a norm that prevents the government from publicly accusing individuals after failing to prove charges in court.

Volume I, which dealt with the 2020 election matter, has already been released, while Volume II now remains sealed inside the Department of Justice. The classified documents prosecution ended in dismissal, and the judge’s order stops the report that would have relitigated the outcome in the public square. That outcome leaves the agency with the report but without permission to hand it to the public outside the Justice Department.

That now is the practical state of play: a judge blocked a post-dismissal report from being disseminated, keeping the content within the department and preventing a prosecutor’s narrative from supplanting the absence of a conviction in public judgment. That’s not obstruction. That’s the law.