In 2011,a federal appellate court in the case of Chevron Corp.v.Berlinger,involving a documentary called "Crude" made by Joseph Berlinger,held that Berlinger could not assert a journalistic privilege because

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The court held that Berlinger could not assert a journalistic privilege because he lacked journalistic independence, as he had allowed the subjects of the documentary to exercise editorial control.

In 2011,a Federal Appellate Court in the Case of Chevron