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On Tuesday, there was a flurry of activity in special counsel Jack Smith’s defunct classified-documents case. Florida-based U.S. District Court Judge Aileen Cannon—who dismissed the case six months ago—issued an order blocking Smith from publicly releasing a final report of his investigation. And though President-elect Donald Trump was quick to claim victory, from a press conference he was holding at Mar-a-Lago, the story of this report is a little more complicated than meets the eye.

Special counsels have a long history of releasing final reports after concluding their investigations. Robert Mueller released his report—into Trump’s efforts to coordinate with Russia after the 2016 election—while Trump was president. Last February, Robert Hur released his report about classified documents found in President Joe........

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