Judge rules release of Jack Smith’s classified docs report would be ‘manifest injustice’ to Trump

A federal judge on Monday permanently blocked the release of special counsel Jack Smith’s report on his investigation into President Donald Trump’s handling of classified documents, preventing public disclosure of one of the most legally and politically significant criminal cases brought against a then-former American president.

U.S. District Judge Aileen Cannon, a Trump appointee, granted the president’s request to keep the report sealed, ruling that its release would present a “manifest injustice” to Trump and his two co-defendants. 

Attorney General Pam Bondi had already declared the report a privileged and confidential internal document that should not be released outside the Justice Department. Cannon’s order goes further, binding even Bondi’s successors at the department.

The classified documents case alleged that Trump illegally retained sensitive government records at his Mar-a-Lago estate in Palm Beach, Florida, after leaving the White House following his first term, and that he obstructed the government’s efforts to retrieve them. The indictment — which included dozens of felony charges — accused Trump of enlisting aides and lawyers to help hide records demanded by investigators and of showing a Pentagon “plan of attack” and a classified map to visitors.

Smith was appointed special counsel in November 2022 by then-Attorney General Merrick Garland to investigate both the documents case and Trump’s efforts to overturn the 2020 presidential election ahead of the Jan. 6, 2021, Capitol riot. Both investigations produced criminal indictments, but Smith’s team abandoned the cases after Trump won the November 2024 election, citing longstanding Justice Department policy against prosecuting a sitting president.

Cannon had previously dismissed the classified documents case in 2024, ruling that Smith had been unlawfully appointed because he was neither nominated by the president nor confirmed by the Senate — a decision Smith’s team appealed to the 11th U.S. Circuit Court of Appeals, calling it “at odds with widespread and longstanding appointment practices.”

Smith produced a two-volume report covering his investigations into both the classified documents matter and the election interference probe. The first volume, addressing the election interference case, was released shortly before Trump returned to the White House, but the volume concerning the documents investigation has remained under seal since Cannon issued a temporary injunction blocking it.

First Amendment advocates and watchdog groups that have pushed for the report’s release may still pursue the matter in higher courts.