9A

There is no statutory or case law addressing this issue.

The Privacy Protection Act (42 U.S.C. 2000aa) has been effective in preventing newsroom searches in Georgia. Although there is no similar provision under Georgia law (apart from the reporter's privilege), the authors are unaware of any newsroom search or seizures of camera equipment or film in Georgia in which the Privacy Protection Act had to be invoked.

Montana has no statutory equivalent to the federal Privacy Protection Act, though it has strong privacy protections in its constitution at Article II, § 10. There has not been litigation on this precise issue.

There is no statutory or case law on the topic of newsroom searches.

No reported federal cases in the Seventh Circuit have discussed 42 U.S.C. 2000aa or searches of journalists' offices.

There is no authority in Hawai'i regarding newsroom searches.

There are no reported cases in which the federal Privacy Protection Act, 42 U.S.C. § 2000-AA, which drastically limits searches of newsrooms, has been construed in North Carolina. There are no similar provisions under state law.

Article 18 of the Texas Code of Criminal Procedure Texas provides statutory protection for newsrooms from search warrants. In particular, Article 18 provides:

A search warrant may not be issued … [for items] in an office of a newspaper, news magazine, television station, or radio station, and in no event may property or items … be legally seized in any search pursuant to a search warrant of an office of a newspaper, news magazine, television station, or radio station.

The Eighth Circuit overturned a decision for the news media over the execution of a search warrant, finding that the district court had to examine the exceptions more closely. Citicasters v. McCaskill, 89 F.3d 1350 (8th Cir. 1996).

This author is unaware of any post- Zurcher v. Stanford Daily, 436 U.S. 547, 3 Med. L. Rptr. 2377 (1978) searches occurring in Iowa newsrooms. Iowa has no specific statutory provisions regarding searches of newsrooms. In Lambert v. Polk County, 723 F. Supp. 128, 16 Med. L. Rptr. 2414 (S.D. Iowa 1989), police officers seized a video tape of a fight in which a fatality occurred made by a home videographer. The police obtained the video by representing that the tape would be returned to the home videographer within two days. Id. The U.S.