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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.

The privilege statute is limited to a "journalist," a term which the statute defines. Governmental entities or persons employed by them who are "engaged in governmental information activities" are excluded from the term "journalist."

The jurisdiction's case law suggests that the privilege applies to members of the news media. As shown below in section A.1.a., this jurisdiction does not narrowly restrict members of the news media to those persons working for established publications or programs. Rather, the courts look more broadly to whether the person who seeks to invoke the privilege intended to disseminate the information to the public.

California's reporter's privilege explicitly protects (1) "[a] publisher, editor, reporter, or other person connected with or employed upon a newspaper, magazine, or other periodical publication or by a press association or wire service, or any person who has been so connected or employed" and (2) "a radio or television news reporter or other person connected with or employed by a radio or television station, or any person who has been so connected or employed." Cal. Const. art. I, § 2(b). Consequently, it is unclear whether it protects other types of journalists, such as book authors.

Oregon's reporter's privilege extends to every person engaged in any medium of newsgathering.

The First Circuit has extended the reporter's privilege to cover parties other than those engaged in traditional journalism and reporting, such as professors and research analysts. In particular, the courts have extended the privilege to publications where the author intends, at the time of his research, to publicly disseminate the information.

The Shield Law broadly defines a newsperson as "any member of the mass media and any employee or independent contractor of a member of the mass media who is engaged to gather, receive, observe, process, prepare, write or edit news information for dissemination to the public through the mass media." C.R.S. § 13-90-119(1)(c).