IV. Who is covered

In Matera, the Arizona Court of Appeals held that the Arizona Media Subpoena Law applies only "to persons who gather and disseminate news on an ongoing basis as part of the organized, traditional, mass media." 170 Ariz. at 448, 825 P.2d at 973. Accordingly, the court ruled that the statute did not apply to an author involved in writing a book about an undercover figure that led to criminal prosecution of several politicians, where the author was not actively and regularly engaged in gathering and reporting the news. 170 Ariz. at 448, 825 P.2d at 973.

However, the Matera court went on to consider the application of the Arizona Shield Law to the author, and did not hold the shield statute inapplicable because of the author's status. Instead, the court found that the statute did not protect the author because he failed to demonstrate that complying with the subpoena would result in the disclosure of confidential sources of information. 170 Ariz. at 450, 825 P.2d at 975.