Trump-appointed judge Aileen Cannon blocked the public from reading Smith's classified documents report

On January 21, 2025 — the day after Trump's inauguration — Judge Aileen Cannon issued an order barring the Justice Department from publicly releasing Volume 2 of Special Counsel Jack Smith's final report. Volume 2 covers Smith's investigation of Trump's retention of hundreds of classified national security documents at his Mar-a-Lago resort and his alleged obstruction of the FBI's efforts to recover them. Cannon, a Trump appointee who dismissed the criminal case in July 2024 by ruling Smith was unlawfully appointed as special counsel, gave Trump's lawyers standing to block the report's release even after the case was closed and Trump had been re-elected.

The Eleventh Circuit Court of Appeals stepped in on October 31, 2025, finding Cannon had shown "undue delay" in ruling on motions filed by the Knight First Amendment Institute at Columbia University and the watchdog group American Oversight. The appeals court gave Cannon a 60-day deadline, falling on or about January 2, 2026, to resolve those motions. Cannon missed the deadline and in late December 2025 declined to lift the injunction, instead ruling that organizations like the Knight Institute lacked standing even to appear in the proceedings.

American Oversight appealed to the Eleventh Circuit, arguing Cannon's order could clear the path for Trump to permanently destroy the report. The classified documents case involved evidence that Trump stored hundreds of highly classified documents at Mar-a-Lago in a bathroom and a ballroom, transferred them to obstruct the government, and directed aides to lie to federal investigators. Trump's co-defendants in the case — his valet Walt Nauta and Mar-a-Lago property manager Carlos De Oliveira — saw their charges dropped when Smith dismissed the case in January 2025.