Maryland's Shield Law was most recently amended in 1988, in response to the decision in Tofani v. State, 465 A.2d 413, 9 Media L. Rep. 2193 (Md. 1983). Tofani concerned a journalist who had written and published several articles about sexual assaults in prison. 465 A.2d at 414. The journalist quoted and identified several of the victims and assailants. Id. When the journalist was subpoenaed to testify before a grand jury regarding the accuracy of her articles, she refused to disclose the names of her sources, on the basis of Maryland's Shield Law. Id. Denying the journalist's motion to quash, the Court held that the journalist waived her privilege by publishing those names in the press. Id. at 417-18. In response, the Maryland legislature added a broad anti-waiver provision to other 1988 amendments, absolutely prohibiting the compelled disclosure of the identity of sources, even if their identities have been published. See Md. Cts. & Jud. Proc. Code Ann. § 9-112(e). The 1988 amendments also raised the standard of proof applicable in seeking to overcome the statutory qualified privilege against compelled disclosure of "news or information," requiring proof by "clear and convincing evidence." Md. Cts. & Jud. Proc. Code Ann. § 9-112(d)(1).