2B

The Constitution of Virginia does not contain an express shield law provision, nor has one been read into any provision.

There is no express shield law type language in the Idaho Constitution. However, the Idaho Constitution has been relied upon in the most significant Idaho decision recognizing a limited reporter's privilege. In In re Wright, 108 Idaho 418, 700 P.2d 40 (1985), three of the four justices in the majority agreed that Art. 1, § 9 of the Idaho Constitution provides a basis for the reporter's privilege. Art. 1, § 9 is the "free speech/free press" provision of the state constitution.

The Nebraska Constitution has no express shield law provision, and none has been implied from the State Constitution by the courts.

Vermont's Constitution provides in relevant part that: "That the people have a right to freedom of speech, and of writing and publishing their sentiments, concerning the transactions of government, and therefore the freedom of the press ought not to be restrained." Vermont Constitution, Chap. I, Art. 13 (July 9, 1793).

Although the Illinois State Constitution does not contain express language establishing a reporter's privilege, it does guarantee freedom of the press in article 1, section 4. In drafting the Statute, the Illinois legislature incorporated these free press guarantees. See People ex. rel. Scott v. Silverstein, 89 Ill. App. 3d 1039, 1042, 412 N.E.2d 692 (1980), rev'd in part on other grounds, 87 Ill. 2d 167, 429 N.E.2d 483 (1981), Villeda v. Prairie Material Sales Inc., 17 Media L. Rep. 2289, 2293 (Ill. Cir. Ct. 1990).

Although the New Hampshire constitution has no express shield provision, the New Hampshire Supreme Court has recognized a qualified privilege to withhold the identity of confidential news sources.

Although the state constitution contains a strong freedom of the press section the courts have never found a newsperson's privilege originating in the state constitution.

There is no state constitutional provision expressly providing shield law protections in Washington State.