Judith Miller of the New York Times was jailed for declining to identify a source because:

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Judith Miller was jailed because she was not protected by any shield law, a federal appeals court ruled she was not protected by any reporter's privilege based on the First Amendment, the Supreme Court declined to hear her case after lower courts ruled against her, and the prosecutor stated her testimony was needed in a grand jury investigation. All these factors contributed to her incarceration for refusing to identify a source.

Judith Miller of the New York Times Was Jailed for Declining