A federal appeal court found that a Florida federal judge had been too slow in resolving months-old requests to lift her order blocking full disclosure of a US Justice Department report on the criminal investigations into US President Donald Trump and gave her 60 days to act.

In a brief, unsigned ruling on Monday, a three-judge panel said US District Judge Aileen Cannon had yet to deal with motions filed in February by two liberal-leaning advocacy groups seeking the second volume of ex-special counsel Jack Smith’s final report. Cannon had barred disclosure in January.

The 11th US Circuit Court of Appeals judges said the organisations had “established undue delay” by Cannon in responding to their requests. But the panel said it would give her another two months to act before ruling on whether to lift her earlier order.

The fight over the Smith report is one of the last unresolved elements of the special counsel’s defunct criminal cases against Trump.

After months of silence following his formal exit from the Justice Department, Smith recently returned to the spotlight to defend his office’s work and criticise actions by the Justice Department under Trump. The president has called him a “criminal”.

Smith’s office brought two sets of charges against Trump. Neither made it to trial before he won re-election in November 2024. Smith then dropped his pursuit of both indictments based on a Justice Department policy against prosecuting sitting presidents.