Trump Aileen Cannon Permanently Blocks Release of Special Counsel’s Second-Volume Report
On Monday, Feb. 23, 2026, U. S. District Judge Aileen Cannon issued a permanent order preventing the Justice Department from releasing the second volume of former special counsel Jack Smith’s final report on President Trump’s handling of sensitive government documents. The decision halts a planned public release and underscores judicial protection of evidence tied to a dismissed prosecution.
Development details — Trump Aileen Cannon order
Judge Cannon granted requests from President Trump and two former co-defendants, Walt Nauta and Carlos de Oliveira, to bar disclosure of the second volume. The order explicitly prevents Attorney General Pam Bondi and her successors from releasing or sharing that portion of the final report. Without the injunction, the second volume had been set to become public on Tuesday.
Cannon grounded the ruling in two concrete legal steps she previously took: she found in July 2024 that Jack Smith had been unlawfully appointed special counsel and dismissed the criminal charges against Mr. Trump in that documents case. Smith appealed that decision, but the prosecution did not proceed after Mr. Trump won a second term. Bondi had already determined that the second volume should not be released, citing questions about the legality of the special counsel appointment.
In her written decision, Cannon noted the second volume contains "voluminous discovery" that remains subject to a protective order issued earlier in the prosecution. She warned that permitting release would result in large amounts of material tied to the investigation becoming public. Cannon also emphasized the presumption of innocence for the former defendants, writing that the court would not take actions that contravene that protection absent a statutory or other lawful directive.
Context and escalation
The judge’s latest move follows the trajectory of the case: initiation of an indictment by the special counsel, Cannon’s July 2024 ruling finding the appointment unlawful and dismissing charges, and subsequent appellate and political developments that halted further prosecution. Special Counsel Smith appealed the dismissal, but the broader prosecution concluded after the presidential transition in which Mr. Trump secured a second term.
Attorney General Bondi’s prior decision not to release the second volume framed the dispute heading into the court challenge. Cannon’s order formalizes that restraint by converting an executive determination into a binding judicial prohibition on sharing the material named in the report’s second volume.
Immediate impact
The immediate effect is to keep sealed the portion of the final report that details the investigation into alleged mishandling of classified material and purported obstruction related to that probe. The named defendants—President Trump, Walt Nauta and Carlos de Oliveira—now have a court-backed barrier against public dissemination of grand-jury materials and discovery tied to the case.
Statements from legal representatives accompanied the ruling: Kendra Wharton, one of Mr. Trump’s lawyers, praised the decision as protecting defendants from publication of grand jury testimony, discovery materials and unproven accusations by what she described as an unconstitutional prosecutor. A spokesperson for Special Counsel Smith declined to comment, and the Justice Department did not immediately respond to requests for comment.
Forward outlook
With the court’s permanent order in place, the second volume will not be released on the previously scheduled public date. The written decision makes clear that, absent a statutory directive or other lawful authority compelling disclosure, the court will maintain the protective posture it has taken. That approach preserves the protective order that covers the discovery materials Cannon cited.
What makes this notable is that the ruling converts an executive determination into a judicial prohibition, directly tying the earlier finding of unlawful appointment and dismissal of charges to the decision to block public access. The timing matters because the order came the day before the second volume was to be made public, immediately altering the planned disclosure timetable and leaving the Justice Department barred from sharing those materials unless the court’s directive changes through future lawful processes.
