Trump Defeats Effort to Stop Mar-a-Lago Judge From Burying Special Counsel Report

The 11th Circuit Court of Appeals denied a request from two groups to stop Judge Aileen Cannon from permanently blocking the release of Volume II of the special counsel's report.

Mar. 12, 2026 at 1:37pm

Got story updates? Submit your updates here. ›

Former President Donald Trump is celebrating a victory after the 11th U.S. Circuit Court of Appeals denied a request from two groups, American Oversight and the Knight First Amendment Institute at Columbia University, to stop Judge Aileen Cannon from permanently blocking the release of Volume II of the special counsel's report on the classified documents case. The appeals court ruled that the groups did not show a "clear and indisputable" right to the writ of mandamus they sought.

Why it matters

This decision is a setback for efforts to make the special counsel's report public, as Judge Cannon had previously blocked the Department of Justice from releasing or sharing Volume II of the report. The ruling suggests the fight over the report's release is far from over, with an appeal of Cannon's initial denial of the groups' intervention still pending.

The details

The 11th Circuit panel, composed of two Trump-appointed judges and one Obama appointee, agreed that the two groups did not meet the high bar required for a writ of mandamus. While the panel said Cannon's order did not render the petition moot, they found the groups failed to show a "clear and indisputable" right to the relief they sought. A concurring judge, however, denied the mandamus petition on the understanding that Cannon would not order the destruction of Volume II while the appeal is pending.

  • On February 28, 2026, Judge Aileen Cannon blocked the DOJ from releasing, sharing, or transmitting Volume II of the special counsel's final report.
  • On March 8, 2026, the 11th Circuit Court of Appeals denied the request from American Oversight and the Knight First Amendment Institute to stop Cannon's order.

The players

Donald Trump

The former president who was the subject of the special counsel's investigation into the handling of classified documents.

Judge Aileen Cannon

The Trump-appointed federal judge who previously dismissed the case against Trump and blocked the release of Volume II of the special counsel's report.

American Oversight

A nonpartisan, nonprofit watchdog group that petitioned the court to stop Judge Cannon from permanently burying the special counsel's report.

Knight First Amendment Institute at Columbia University

A nonpartisan organization that advocates for free speech and press freedom, which also petitioned the court to stop Judge Cannon's order.

Jack Smith

The special counsel who investigated the handling of classified documents at Mar-a-Lago.

Got photos? Submit your photos here. ›

What they’re saying

“Petitioners have not met that burden here, as they have not shown that they have no other adequate means to attain the relief they seek.”

— U.S. Circuit Judges Andrew Brasher, Robert Luck, and Adalberto Jordan, 11th Circuit Court of Appeals Judges (Law&Crime)

“The American people have a right to this extraordinarily significant report, and the First Amendment and common law require its release. We're hopeful that the court will overrule Judge Cannon and order the release of the Special Counsel's report.”

— Scott Wilkens, Knight Institute Senior Counsel (Law&Crime)

“Judge Cannon's recent ruling protects the rights of President Trump and others wrongfully targeted by Jack Smith's unlawful and unconstitutional investigation.”

— Kendra Wharton, Trump Attorney (Law&Crime)

What’s next

Oral arguments on the appeal of Judge Cannon's initial denial of the groups' intervention are scheduled for June 2026.

The takeaway

The 11th Circuit's decision is a victory for former President Trump, as it allows Judge Cannon's order blocking the release of Volume II of the special counsel's report to remain in place for now. However, the fight over the report's public release is far from over, with an appeal of Cannon's initial denial of the intervention request still pending.