WASHINGTON (AP) — A federal judge on Monday permanently barred the release of a report by special counsel Jack Smith into his investigation into President Donald Trump’s hoarding of classified documents at his Mar-a-Lago estate.

U.S. District Judge Aileen Cannon, Trump’s nominee to the bench, granted a request by the Republican president to keep secret the report on a criminal investigation once considered to pose significant legal danger to Trump.

In this image from video provided by the U.S. Senate, Aileen M. Cannon speaks remotely during a Senate Judiciary Committee oversight nomination hearing to be judge of the U.S. District Court for the Southern District of Florida on July 29, 2020 in Washington.
In this image from video provided by the U.S. Senate, Aileen M. Cannon speaks remotely during a Senate Judiciary Committee oversight nomination hearing to be judge of the U.S. District Court for the Southern District of Florida on July 29, 2020 in Washington.

US Senate via AP

Smith and his team produced a two-volume report on investigations into Trump’s efforts to overturn the 2020 presidential election after losing to Joe Biden and his withholding of classified documents at his estate in Palm Beach, Florida, after he left the White House after his first term.

Both investigations produced allegations that were dropped by Smith’s team after Trump’s victory in the November 2024 election, in light of long-standing legal opinions from the Justice Department that say sitting presidents cannot face federal prosecution.

Former Justice Department special counsel Jack Smith testifies before the House Judiciary Committee on Capitol Hill in Washington on January 22, 2026.
Former Justice Department special counsel Jack Smith testifies before the House Judiciary Committee on Capitol Hill in Washington on January 22, 2026.

AP Photo/Mark Schiefelbein

Cannon, who in 2024 dismissed the case after concluding that Smith was illegally appointed, said the release of the report would present a “manifest injustice” to Trump and his two co-defendants.

“Special Counsel Smith, acting without legal authority, obtained an indictment in this action and initiated proceedings that resulted in a final order dismissing all charges,” he wrote. “As a result, the former defendants in this case, like every other defendant in this situation, still enjoy the presumption of innocence considered sacrosanct in our constitutional order.”

He said that while it is true that special counsels have historically released reports at the conclusion of their work, they have done so after refusing not to file charges in a particular case or “after adjudications of guilt through plea or trial.”

“The Court struggles to find a situation in which a former special prosecutor released a report after bringing criminal charges that did not result in a guilty plea, at least not in a situation like this, in which the defendants contested the charges from the beginning and still proclaim their innocence.”