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Earlier this week, U.S. District Court Judge Aileen Cannon made a not-so-subtle play for President Donald Trump’s attention. The Southern District of Florida judge—a longtime favorite of Trump’s—issued an order banning the release of a report detailing former special counsel Jack Smith’s criminal investigation into the hoards of boxes filled with classified documents that Trump took on his way out of the White House in 2021. With this decision, Cannon, who was confirmed just weeks before the end of Trump’s first term, went out of her way to rule on a question that she does not technically have jurisdiction over, while simultaneously positioning herself for a promotion—with a looming potential Supreme Court opening quite possibly on Cannon’s mind.

Just to remind you: Before Trump was elected, Judge Cannon slow-walked that investigation for months before ultimately ruling—without precedent and backed by no other court—that Smith had been illegally appointed, so his indictment of Trump had to be thrown out. This was 2024. Cut to this past Jan. 20, when Waltine Nauta and Carlos de Oliveira, Trump’s co-defendants in the classified documents case, submitted a motion requesting that Cannon permanently ban the U.S. Department of Justice from releasing Smith’s final report on his classified documents investigation, widely referred to as Volume II. (Volume I was his final report on his election interference case, which came out in January 2025 just before Trump reentered office.) On Monday Cannon granted that request, with a side of gratuitous attacks on the former special counsel.

Cannon’s order restated that Smith was wrongfully appointed as special counsel—again, she’s the only judge who’s come to this conclusion. She went further, though, accusing Smith of concocting a “brazen stratagem” to “circumvent” her initial ruling by … writing the report per the instructions of the special counsel statute. “To say this chronology represents, at a minimum, a concerning breach of the spirit of the dismissal order is an understatement, if not an outright violation of it,” Cannon wrote.

What Cannon claimed as a personal affront, though, was merely Smith following the law. Throughout the entire history of the special counsel statute, every single one has produced a final report detailing their investigations to the attorney general. And no matter if a Republican or Democratic administration was in power, the report was made public as a form of transparency. Nevertheless, Cannon decided to challenge history and argued that the Department of Justice cannot release Smith’s report because there’s never been a situation where “a former special counsel has released a report after initiating criminal charges that did not result in a finding of guilt, at least not in a situation like this one, where the defendants contested the charges from the outset and still proclaim their innocence.”

That is categorically false. In 2019, former special counsel Robert Mueller conducted an investigation into Russian interference in the 2016 election and found evidence that Trump........

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