Trump Allies Seek to Permanently Block Release of Mar-a-Lago Special Counsel Report

Two groups appeal to 11th Circuit to unseal redacted version of Volume II of Jack Smith's investigation

Published on Feb. 10, 2026

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Former President Donald Trump and his allies are pushing to permanently block the release of the second volume of Special Counsel Jack Smith's report on the Mar-a-Lago investigation. American Oversight and the Knight First Amendment Institute at Columbia University have asked the 11th Circuit Court of Appeals to order the release of a redacted version of Volume II, which has been kept under seal by U.S. District Judge Aileen Cannon for over a year. The groups argue that the rationale for keeping the report sealed no longer exists, as Trump's co-defendants have dropped their appeals and the statute of limitations has expired on the Espionage Act charges.

Why it matters

The battle over the release of the Special Counsel's report highlights the ongoing political tensions surrounding the Mar-a-Lago investigation and Trump's efforts to shield information from the public. The report's findings could provide important insights into the probe, but Trump and his allies are seeking to permanently bury the report to prevent any potential damage to the former president.

The details

American Oversight and the Knight First Amendment Institute have asked the 11th Circuit to order Judge Cannon to post a redacted version of Volume II of the Special Counsel's report on her docket. The first volume, related to the January 6th investigation, has been public since January 2025, but the second volume has remained sealed in Cannon's chambers. Cannon, a Trump-appointed judge, initially kept the report sealed to prevent "prejudice" to Trump's former co-defendants, Waltine Nauta and Carlos de Oliveira, who had active appeals. However, those appeals have since been dropped, and the groups argue that there is no longer a valid reason to keep the report sealed.

  • In January 2025, the first volume of the Special Counsel's report was made public.
  • For over a year, Judge Cannon has kept Volume II of the report sealed in her chambers.
  • The five-year statute of limitations on the charges against Nauta and de Oliveira will expire in 2028, before the end of Trump's second term.

The players

Jack Smith

The Special Counsel appointed to investigate the Mar-a-Lago case and the January 6th attack on the U.S. Capitol.

Aileen Cannon

The U.S. District Judge who has kept Volume II of the Special Counsel's report sealed for over a year.

American Oversight

A nonpartisan, nonprofit organization that has asked the 11th Circuit to order the release of the redacted Volume II of the Special Counsel's report.

Knight First Amendment Institute at Columbia University

A nonpartisan organization that has also asked the 11th Circuit to order the release of the redacted Volume II of the Special Counsel's report.

Waltine Nauta

A former Trump valet who was a co-defendant in the Mar-a-Lago case, but has since dropped his appeal.

Carlos de Oliveira

The former Mar-a-Lago property manager who was a co-defendant in the Mar-a-Lago case, but has since dropped his appeal.

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What they’re saying

“For more than a year, Judge Cannon has kept the Special Counsel's final report under seal, long after any legitimate claims by Trump's co-conspirators expired.”

— Chioma Chukwu, Executive Director, American Oversight (American Oversight)

What’s next

The 11th Circuit is expected to rule on the groups' request to order the release of the redacted Volume II of the Special Counsel's report in the coming weeks.

The takeaway

The battle over the release of the Special Counsel's report on the Mar-a-Lago investigation highlights the ongoing political tensions surrounding Trump's efforts to shield information from the public. The report's findings could provide important insights, but Trump and his allies are seeking to permanently block its release to prevent any potential damage to the former president.