6th Cir.

6. Relief

On appeal from a contempt order or a disclosure order, a reporter who has refused to comply with a subpoena should ask the Sixth Circuit to reverse and vacate the contempt judgment or disclosure order.

Whether the Sixth Circuit. would remand to the district court, rather than vacate the orders at issue, is not predictable.

D. Information and/or identity of source

In civil contexts, federal courts within the Sixth Circuit have applied the First Amendment to bar compelled disclosure of a newspaper's confidential sources. Southwell v. Southern Poverty Law Ctr., 949 F. Supp. 1303 (W.D. Mich. 1996); NLRB v. Midland Dailey News, 151 F.3d 472 (6th Cir. 1998).

5. Threat to human life

The court is required to weigh the potential harm, such as ultimate death or bodily injury that might occur as a result of the disclosure of a source's identity. Southwell v. Southern Poverty Law Center, 949 F. Supp. 1303 (1996).