CRIME & LAW

Judge Bars Release of Special Counsel Smith's Second Volume

PUBLISHED Feb 23, 2026, 10:05 AM ET

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Washington. A federal judge on Monday permanently barred the Justice Department from releasing the second volume of special counsel Jack Smith's report detailing his investigation into President Donald Trump's possession of classified documents and alleged obstruction. U.S. District Judge Aileen Cannon granted requests by Trump and co-defendants Walt Nauta and Carlos de Oliveira, saying release would be a "manifest injustice." The order bars Attorney General Pam Bondi and successors from disclosing that portion. Bondi had earlier advised nondisclosure amid questions about Smith's appointment. The charges were dismissed after Cannon's July 2024 ruling. Based on 6 articles reviewed and supporting research.

By Adyan K. | JQJO News

Timeline of Events

2023: Special Counsel Jack Smith's investigations produced indictments related to classified documents and election efforts.
July 2024: Judge Aileen Cannon ruled Smith was unlawfully appointed and dismissed charges in the classified documents case.
November 2024: Smith's teams abandoned further prosecution following President Trump's election to a second term.
Pre-2026: Attorney General Pam Bondi determined the second volume should not be released publicly amid legal questions.
Monday, 23 February 2026: Judge Cannon permanently barred release of the second volume of Smith's report.

News Intelligence

This case impacts your rights. It's about government transparency and the public's right to know. You can follow similar cases to understand how courts balance privacy and public interest.

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Articles Published:: 10
Right Leaning:: 0
Left Leaning:: 0
Neutral:: 10
Distribution:: Left 0%, Center 100%, Right 0%

Who Benefited

President Donald Trump and his two co-defendants, Walt Nauta and Carlos de Oliveira, directly benefited because the court order prevents public disclosure of the second volume of Special Counsel Jack Smith's report, preserving the confidentiality of allegations that were part of a dismissed prosecution.

Who Impacted

The public, journalists and transparency advocates suffered reduced access to investigatory findings and factual detail when a court permanently barred release of the report portion that outlined allegations and investigative reasoning.