Reynolds, a paralegal, appealed a contempt ruling after she refused to submit an unpublished document for discovery. The Second Circuit Court of Appeals upheld the contempt order. The Court reasoned that a person who had gathered information for private use without the intent to gather the information as part of an investigation for a publication was not entitled to a reporter's privilege.

See also

• The 1st Amendment
• Branzburg v. Hayes
• In re Madden