2D

There are no other sources of a reporter's privilege in Alabama, but as in any case, a court may quash a subpoena on the grounds that the subpoena is unduly burdensome, ALA. R. CIV. P. 45 (c)(3)(A)(iv), or unreasonable, oppressive, or unlawful. ALA. R. CRIM. P. 17.3 (c). See Williams v. State, 489 So.2d 4, 8 (Ala. Crim. App. 1986) (holding that the trial court properly granted a motion to quash a subpoena duces tecum because it was unduly burdensome and the newspaper articles sought were available through other means.)

The common law is the main source for a reporter's privilege in Massachusetts. Courts have recognized, through case law, that a balancing of interests is required when a journalist resists complying with a subpoena. See Petition for the Promulgation of Rules, 479 N.E.2d 154 (Mass. 1985) (asserting that a common law approach to this area of law would be better than rulemaking by the court). See also In re John Doe Grand Jury Investigation, 574 N.E.2d 373 (Mass. 1991); In re Roche, 411 N.E.2d 466 (Mass. 1980); Ayash v.

At this time, there are no other recognized sources for the reporter's privilege in Ohio.

There are no other sources of a reporter's privilege in Arkansas, such as court rules, attorney general opinions, or administrative procedures.

Public Policy -- See Telnikoff v. Matusevitch, 702 A.2d 230, 25 Media L. Rep. 2473 (Md. 1997) (discussing Maryland's strong commitment to freedom of the press).

There are no other state-law sources of a reporter's privilege, such as court rules, state bar guidelines, or administrative procedures.

We have found no other state-law based sources of the reporter's privilege in Arizona.

There are no other sources in Maine relating to a reporter's privilege and in Letellier, supra, the Maine Supreme Court specifically noted the absence of court rules or rules of evidence providing a basis for the privilege.