In a swift ruling, the U.S. Court of Appeals for the D.C. Circuit rejected former President Donald Trump's efforts to block a lower court order that his lawyer, Evan Corcoran, immediately turn over documents subpoenaed by Special Counsel Jack Smith's grand jury in relation to potential national security law violations and obstruction of justice. The documents subpoenaed by the grand jury include attorney notes of conversations between Corcoran and Trump, as well as audio files.

Reports suggest that Trump instructed Corcoran in June 2022 to give a false sworn affidavit to the Justice Department, claiming that no further classified documents responsive to the grand jury's May 2022 subpoena remained at Mar-a-Lago, where Trump had previously kept more than 100 classified documents. However, a court-authorized search of Mar-a-Lago in August 2022 revealed the falsity of the affidavit.

The appellate court decision underscores the peril facing the former president in the ongoing investigation as prosecutors continue to build a case that Trump obstructed efforts by the government to reclaim classified material and that he may have misled his own lawyer. The judicial impatience with the defendant and the swift rejection of Trump's unsound delaying tactics may signal a trend in the coming cases against Trump, making it difficult for him to delay justice being served.