Lower federal and state courts have fashioned a limited First Amendment privilege that often protects reporters who refuse to reveal the names of news sources.Judges seem more willing to grant reporters the use of this privilege in

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Civil actions rather than in grand jury investigations are where judges seem more willing to grant reporters the use of this privilege, reflecting a balancing act between the need for confidentiality in journalism and the demands of legal proceedings.

Lower Federal and State Courts Have Fashioned a Limited First