Grand jury subpoenas are treated the same as any other subpoena under the statute. See Neb. Rev. Stat. § 86-708(1) (Reissue 1999) noting that grand jury subpoenas shall not suspend or otherwise interfere with the shield law. Nebraska rarely utilizes grand juries. The authors are not aware of any grand jury subpoenas having been issued to reporters.
No Iowa case relates to the reporter's privilege and grand jury subpoenas. Because the Iowa cases so heavily rely on Branzburg, it is likely the privilege would be more easily subordinated in a grand jury context.
The Eastern District of Arkansas in In re Grand Jury Subpoena ABC, Inc., 947 F. Supp. 1314 (1996), held that there is no reporter's privilege in the grand jury context, at least absent bad faith or an abuse of grand jury function. The court found the Supreme Court's decision in Branzburg controlling on the question, interpreting Justice Powell's concurring opinion narrowly.
None of the Idaho decisions has considered the assertion of a reporter's privilege in a grand jury context. However, as noted above, the Wright court specifically stated that the analysis of the privilege should be the same regardless of the case setting.