In most states with shield laws, to overcome a journalist's qualified privilege to withhold notes or the names of sources, the government usually has to show that:

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In most states with shield laws, the government typically must demonstrate that the information sought is clearly relevant to a criminal investigation, there are no other sources for the information, and there is a compelling need for the information to overcome a journalist's qualified privilege to withhold notes or the names of sources.

In Most States with Shield Laws, to Overcome a Journalist's