Jack Smith’s Final Report on Trump Investigations Surfaces in Court Filing, Prompting White House Fury and GOP Recriminations

By Alan Feuer and Adam Goldman The New York Times November 23, 2025

WASHINGTON — In a dramatic courtroom development that has sent shockwaves through the Trump administration, U.S. District Judge Aileen M. Cannon on Friday ordered the partial unsealing of Volume II of special counsel Jack Smith’s final report on the classified documents investigation — a 150-page dossier detailing evidence of President Trump’s alleged mishandling of national security materials at Mar-a-Lago — prompting Mr. Trump to abruptly end a press briefing and fueling insider claims that the long-dormant case has reached a “point of no return.”

The ruling, issued in response to Freedom of Information Act requests from the Knight First Amendment Institute at Columbia University and The New York Times, lifts a January 2025 injunction Cannon had imposed to protect the fair-trial rights of Mr. Trump’s co-defendants, Waltine Nauta and Carlos de Oliveira, whose charges were dismissed with prejudice after Mr. Trump’s 2024 election victory. The report, submitted to Attorney General Merrick B. Garland on January 7, 2025, before Mr. Smith’s resignation three days later, argues that Mr. Trump “would have been convicted” on all counts had the case proceeded to trial, citing “overwhelming evidence” of willful retention and obstruction, including audio recordings of the president discussing classified submarine schematics with unauthorized individuals.

The unsealing, which Cannon described as “necessary to vindicate public interest in transparency absent ongoing proceedings,” includes redacted sections on witness interviews and forensic analysis of Mar-a-Lago storage boxes — but leaves unredacted a damning timeline of FBI retrieval efforts thwarted by Mr. Trump’s team. “This isn’t mere negligence; it’s a pattern of deliberate evasion,” Mr. Smith wrote in the report, released in full by the Knight Institute shortly after the order. The document also rebukes Cannon’s July 2024 dismissal of the indictment as “unlawful appointment,” calling it a “frivolous delay tactic” that “shielded the defendant from accountability.”

The fallout was immediate and visceral. During a midday briefing on the partial government shutdown — now in its 12th day — White House press secretary Karoline Leavitt was defending Mr. Trump’s executive order revoking security clearances for Mr. Smith’s former team when Rep. Jamie Raskin, the Oversight Committee ranking member, interrupted via C-SPAN feed with a pre-recorded statement: “Jack Smith’s report isn’t buried anymore — it’s exhumed. The evidence trembles with the weight of obstruction; no amount of delay can hide it.” Mr. Trump, visible in the background flipping through briefing papers, suddenly stood, face ashen, and rushed from the room, barking to an aide: “Turn this off — it’s a hoax!” Ms. Leavitt, left scrambling, called the unsealing “a partisan stunt by deep-state holdovers,” but the clip, viewed 14 million times on X within hours, trended under #SmithUnleashed, with users splicing it with Mr. Trump’s 2023 mug shot.

Behind closed doors, the White House descended into “full-blown panic mode.” Four officials, speaking on condition of anonymity, described Mr. Trump convening an emergency call with Attorney General Pam Bondi and FBI Director Kash Patel at 2:15 p.m., where he reportedly thundered: “Smith’s a traitor — why didn’t we shred this? Get Cannon on the phone; reverse it now!” Ms. Bondi, whose DOJ inherited the files after Mr. Smith’s exit, assured him the report contained “no new bombshells” and that her office’s parallel probe into “Democrat enablers” would counterbalance it, but insiders say the president views the timing — amid Epstein scrutiny and shutdown brinkmanship — as sabotage. “This case hit a point of no return,” one adviser confided. “Smith’s evidence isn’t dead; it’s resurrected for midterms.”

Republicans scrambled into damage control. House Speaker Mike Johnson, facing a caucus revolt over the shutdown, held an urgent conference call Saturday, urging members to frame the report as “vindication” — noting its confirmation that Mr. Trump’s actions were “official acts” immune under the Supreme Court’s 2024 ruling — but fractures deepened. Rep. Marjorie Taylor Greene tweeted: “Smith’s report is a witch hunt remix — but if it exposes Biden holdovers, release it all!” drawing rebukes from MAGA hardliners like Steve Bannon, who blasted her on his podcast as “going soft on the deep state.” Senator Lindsey Graham, on Fox News Sunday, defended Mr. Trump but conceded: “The optics are brutal — Cannon needs to seal this back up fast.”

Democrats seized the moment. Senate Judiciary Chairman Dick Durbin demanded a full hearing on the report’s implications for presidential immunity, tweeting: “Smith’s trembling evidence isn’t buried — it’s exhumed. Trump can’t outrun obstruction forever.” The unsealed sections detail 11 sets of classified documents recovered from Mar-a-Lago, including nuclear secrets, and Mr. Trump’s recorded admission: “It’s highly confidential… but it’s not like a spy thing.” Mr. Smith’s conclusion: “The evidence is overwhelming; conviction was inevitable absent extraordinary delays.”

The political firestorm has eroded Mr. Trump’s already fragile footing. A Quinnipiac poll released Saturday shows his approval at 37 percent — a second-term nadir — with independents citing “ethical lapses” as a top concern, amplified by the Epstein files’ shadow and shutdown fatigue. Late-night hosts feasted: Jimmy Kimmel replayed Mr. Trump’s exit, quipping: “He rushed out like he did with those boxes — but evidence doesn’t stay hidden in a ballroom forever.”

For Mr. Trump, who revoked Mr. Smith’s team clearances in February via executive order, the report’s resurrection — via Cannon, his own appointee — stings as betrayal. Aides are modeling responses: a prime-time address dismissing it as “hoax 2.0,” per sources. Yet with midterms 11 months away and the Epstein deadline looming, insiders murmur of a “term collapse”: “Smith’s evidence isn’t prosecutable now, but it’s politically fatal.”

As Washington braces, Cannon’s next ruling — due in 60 days per a recent appeals court order — looms large. In a presidency defined by defiance, Friday’s courtroom quake may prove the tremor that topples the tower — evidence, once buried, refusing to stay down.