IV. Who is covered

There are no state decisions defining "reporter," "news" or similar terms. The decision in Silkwood, which involved the privilege claim of a documentary film maker, suggests that the Tenth Circuit will define these terms somewhat liberally, to the extent it is necessary to define them. Indeed, in the subsequent case of Grandbouche v. Clancy, 825 F.2d 1463 (10th Cir. 1987), the court recognized the qualified First Amendment privilege rights of an individual who did not claim to be a news gatherer or representative of any communications medium.