The ‘Bundt Cake Recipe’ Leaker of Jack Smith’s Report Could Face Judge Cannon’s Wrath for Violating Her Order

The request by the Department of Justice that Judge Aileen Cannon “consider further action” against a former prosecutor who emailed herself a contraband copy of Special Counsel Jack Smith’s Mar-a-Lago report underscores the Trump administration’s relentless focus on the dispatch.The “notice of alleged violation of court order” was docketed on Wednesday in the Southern District of Florida, where Mr. Smith brought his criminal case against Mr. Trump for the storage of classified documents at Mar-a-Lago. The special counsel accused Mr. Trump of dozens of violations of the 1917 Espionage Act, charges that could have put Mr. Trump behind bars for decades.The case, which some reckoned to be the strongest of the four criminal ones levied at Mr. Trump, was dismissed after Judge Cannon, an appointee of the president, found that Mr. Smith was unlawfully appointed by Attorney General Merrick Garland. The special counsel appealed that ruling, but the petition was dropped after Mr. Trump regained the White House. Boxes of records stored in a bathroom and shower at President Trump’s Mar-a-Lago estate, Palm Beach. Justice Department via APThe special counsel regulations under which Mr. Smith mandated that he complete a “confidential report explaining the prosecution or declination decisions reached by the Special Counsel.” Discretion about whether to release that report — if it “would be in the public interest” — is assigned to the attorney general. Mr. Garland quickly authorized the publication of Mr. Smith’s report about the January 6 case. The one about Mar-a-Lago, though , has taken a more tortured path.Mr. Garland’s first notion was to release it “in camera” — meaning in secret — to a select group of lawmakers. The sticking point was that the appeal with respect to Mr. Trump’s two employees and co-defendants — the valet Waltine Nauta and the property manager Carlos De Oliveira — was still active when Mr. Trump took office. He eventually withdrew the appeal, ending the case. Litigation over the fate of the report, though, has stretched for years. Two watchdog groups, American Oversight and the Knight First Amendment Institute at Columbia University, have argued in court that the document should be released now that the case is over. They cite freedom of information statutes as well as the public’s constitutional prerogative to view court documents. The DOJ, though, has argued that the report should suffer “constitutional expungement” — meaning destruction — and that it ought to be “consigned to the dustbin of history.” In February, Judge Cannon “permanently blocked” the report’s release. She found that its publication would cause “irreparable damage” and create a “manifest injustice” given that Messrs. Trump, De Oliveira, and never faced a jury. Judge Cannon also had harsh words for Mr. Smith. Her ruling accused him of engaging in a “brazen stratagem” by typing up his report even after he had been disqualified from the case. She calls that “a concerning breach of the spirit of the Dismissal Order is an understatement, if not an outright violation of it.” Mr. Trump’s lawyer, Kendra Wharton, declared that “Judge Cannon’s courage and judicial resolve on these important due process issues should be recognized and taught in law school classrooms across America.”Judge Cannon stopped short of ordering the report’s destruction, meaning that it could yet be released if a higher court orders. Her ruling has already been appealed to the 11th United States Appeals Circuit, which has set oral arguments for September 28. The 11th Circuit has not demurred from overruling Judge Cannon before. At an inchoate stage of this case it rejected her determination that a special master was required to oversee the government’s collection of evidence from Mar-a-Lago. Last month, a former federal prosecutor in Judge Cannon’s district Carmen Mercedes Lineberger, was criminally charged, “in separate instances in late 2025,” with emailing herself copies of Mr. Smith’s report. The indictment alleges that Ms. Lineberger “concealed the true identity of an electronic copy of the Volume II Report” by labeling them “chocolate cake recipe” and “bundt cake recipe.” In doing so she “altered the electronic file names of government records,” which is a crime.Ms. Lineberger has pleaded not guilty to theft, record alteration, and concealment charges. The DOJ writes to Judge Cannon in its notice that the filing is meant “to enable this Honorable Court to consider further action and sanction as deemed appropriate.” Judge Cannon could initiate separate criminal contempt charges against Ms. Lineberger for violating her order. A conviction on contempt charges could result in yet more prison time.The Knight Institute emailed the Sun a statement declaring that “Judge Cannon’s justifications for permanently suppressing the Special Counsel’s report don’t withstand scrutiny. The report is a government record of profound public importance that must be released. The public has the right to see this report under the First Amendment, common law, and Freedom of Information Act. It’s that simple.”

The ‘Bundt Cake Recipe’ Leaker of Jack Smith’s Report Could Face Judge Cannon’s Wrath for Violating Her Order

The ‘Bundt Cake Recipe’ Leaker of Jack Smith’s Report Could Face Judge Cannon’s Wrath for Violating Her Order

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