In West Virginia, there have been no cases addressing penalties for noncompliance in a libel case. From the Hudok case, it is known that a qualified privilege does exist in West Virginia, even in libel cases. Nevertheless, the privilege is not as strong as in other civil claims. Stated another way, the burden a litigant must meet to breach the reporter's privilege is less in cases where defamation or libel is alleged. Although the Hudok court did not delineate the boundaries of the privilege in the defamation context, it did cite to Zerilli v.