The Capitol Riot, Infowars, and the Definition of Journalism

Earlier this summer, Attorney General Merrick Garland announced revisions to the Department of Justice internal rules on obtaining records from journalists. With limited exceptions, the policy provides that DOJ will not subpoena information from members of the “news media” who were engaged in “newsgathering activities.” Now a case arising from the January 6 Capitol riot has highlighted a question posed by this policy: who qualifies as a member of the news media entitled to its protections? More specifically: is the conspiracy-touting, right-wing website Infowars engaged in journalism? The answer to this question has implications far beyond cases involving the insurrection at the Capitol.

The Owen Shroyer Case

Jonathon Owen Shroyer is the host of a daily program that streams on Infowars, “The War Room with Owen Shroyer.” Infowars is a “news service” website led by Alex Jones. Jones and Infowars are noted for promoting various conspiracy theories, including that the 2012 shooting of twenty children and six adults at Sandy Hook elementary school was faked and that a Washington, D.C. pizza parlor housed a child sex trafficking ring associated with Hillary Clinton – a conspiracy hoax that became known as “Pizzagate.” Jones, Shroyer, and Infowars have been banned from most social media sites for spreading disinformation.

Infowars was a favorite of former president Trump, who routinely praised Jones and echoed the site’s outrageous claims. Infowars also played a significant role in helping perpetuate the “big lie” that the 2020 presidential election was stolen. After Trump lost re-election, Shroyer led a nine-city tour of “Stop the Steal” rallies. He was also featured in materials published by Infowars promoting the January 6, 2021 rally in Washington and urging people to attend and “fight for Trump.”

Exhibit from the Shroyer Arrest Warrant

On January 5, Shroyer spoke at a rally at Freedom Plaza in D.C. where he said, “Americans are ready to fight! . . . We are the new revolution!” Video footage allegedly shows him taking part in marching to the Capitol on January 6, exhorting the mob to stop the election from being “stolen,” and leading the crowd in a chant of “1776!” At one point during the rally, he called live into an Infowars broadcast and reported, “They’ve taken the Capitol grounds, they’ve surrounded the building itself, they’re on the actual building structure. . . . We literally own these streets right now.”

Last week, Shroyer was arrested for his role in the Capitol riot and appeared in court in Washington, D.C. Prosecutors have charged him with entering a restricted area of the Capitol and with unlawfully attempting to impede the work of Congress. Both offenses are misdemeanors. It appears he will maintain that he was covering the events in Washington as a journalist for Infowars.

The Judge’s Inquiry

On August 19, U.S. Magistrate Judge Zia Faruqui held a telephone conference with prosecutors regarding the arrest warrant for Shroyer. Faruqui asked prosecutors whether they considered Shroyer a member of the news media and whether they had complied with the new DOJ media regulations when investigating him. Prosecutors said they had followed the guidelines, but declined to provide specifics. This caused Faruqui to issue an opinion a few days later, expressing his displeasure. He claimed that prosecutors in other cases have provided more details about their compliance with the regulations, and it troubled him they did not do so here: “The Department of Justice appears to believe that it is the sole enforcer of its regulations. That leaves the court to wonder who watches the watchmen.”

Faruqui’s opinion is a little odd, in that it doesn’t order the prosecutors to do anything. He ultimately signed the arrest warrant, concluding that even if Shroyer was a journalist there was ample evidence that he committed a crime. It appears Faruqui just wanted to make a clear record of his request and of his concerns about whether DOJ was in fact following its own media guidelines.

In a letter to the court, John Crabb, Jr., Chief of the Criminal Division at the U.S. Attorney’s Office, responded with the polite legal equivalent of, “Buzz off.” Crabb wrote that enforcing internal regulations like the media guidelines is committed to DOJ’s sole discretion. It is not the court’s role, he argued, to police DOJ’s application of internal policies that have nothing to do with the finding of probable cause. He also argued that such inquiries by the court might impede “frank and thoughtful deliberations within the Department” about how to apply the regulations.

Crabb is clearly right here, and Faruqui was out of line. The DOJ “Justice Manual” contains many policies about how to interpret and enforce certain areas of the law. Department attorneys may be subject to internal discipline for failing to follow those policies. But it is well-established that those policies do not create rights that may be enforced by outside parties. These are voluntary internal operating rules, not laws passed by Congress.

If Shroyer believes he has some kind of First Amendment defense based on his alleged status as a journalist, he can file a motion and the judge can rule on it. But under the separation of powers, it’s not Faruqui’s role to probe DOJ’s application of its own voluntary policies that have nothing to do with the legal merits of the case. At some level Faruqui himself seems to recognize this, since he issued his opinion but did not require DOJ to do anything in response.

US Dept of Justice
U.S. Department of Justice

DOJ’s Media Guidelines

As noted above, Faruqui’s inquiry was based on DOJ’s recently-modified guidelines about subpoenas to members of the media. Those guidelines have been around in various forms for decades. They represent the Department’s effort to balance the needs of law enforcement with the important First Amendment interests of the news media in gathering information without fear of government interference or punishment.

Journalists have long argued that they should have a legal privilege to refuse government demands for information about their reporting and sources. They claim such a privilege is necessary to protect the vital role of the free press in rooting out government misconduct. They argue that, absent such a privilege, government leakers and other sources of information who may fear reprisals if discovered will refuse to speak to reporters. Just as communications to lawyers and doctors are shielded from disclosure by the legal system, they argue, communications to journalists should be protected in order to ensure the free flow of information to the public.

[Side note: I think the arguments for the reporter’s privilege are wrong and that the privilege is a bad idea. I’ve written a lot on that topic – including in the very first post on this blog. Those arguments are beyond my scope here, but if you are interested in a deeper dive you can check out my blog posts here, here, and here, and law review articles here and here.]

In the landmark 1972 case of Branzburg v. Hayes, the Supreme Court held that the First Amendment does not create a privilege that allows journalists to refuse to testify, at least in federal criminal proceedings. In the aftermath of Branzburg, DOJ adopted its media guidelines, recognizing that even if the Constitution did not require it, DOJ should recognize the First Amendment interests at stake and exercise its discretion not to pursue information from journalists in most cases.

Battles Over the Reporter’s Privilege

There have been a few high-profile fights between DOJ and journalists who resisted complying with court orders to reveal information about their sources, although overall such cases are quite rare. Perhaps the most notable example involved New York Times reporter Judith Miller, who was jailed for nearly three months in 2005 when she refused to reveal her source to a grand jury investigating the leak of a CIA agent’s identity. (Vice president Dick Cheney’s chief of staff, Scooter Libby, was ultimately convicted of perjury and obstruction of justice in that investigation. Libby was pardoned by president Trump in 2018.)

Another dispute involved yet another New York Times reporter, James Risen, who refused to reveal his source for a story that revealed classified information about a covert U.S. government operation in Iran. Risen took his fight all the way to the U.S. Supreme Court, and the courts ruled he had no privilege and could be compelled to testify. Risen made it clear that he, like Miller, would go to jail rather than comply. The government ultimately backed down, chose not to call him as a witness, and managed to convict the source, Jeffrey Sterling, without Risen’s testimony.

During the Obama administration, the Justice Department under Attorney General Eric Holder was strongly criticized by media organizations for its pursuit of those who leaked classified information to the press. Obama’s DOJ was accused of engaging in a “war on the press” — a ridiculous charge, as I explained here. Nevertheless, responding to that criticism, Holder held meetings with media representatives and updated the DOJ guidelines to make it even more difficult for prosecutors to subpoena information from journalists. In general, such information could be sought only when it was vitally important to the case, when alternative avenues to obtain the information had been exhausted, and when the request was approved by high level DOJ officials.

Early in the Biden administration, DOJ disclosed that Trump’s Justice Department had secretly sought email and phone records of several reporters at the Washington Post, New York Times, and CNN, in connection with investigations of leaks of classified material. When asked about the disclosures, Biden said that seeking such records from journalists was “simply wrong” and that he would not allow it in his administration.

As a result, last July 19, as noted above, Garland issued a memo saying the media guidelines would be amended again and would now contain a flat prohibition on the use of compulsory process to seek information from members of the news media who were engaged in newsgathering activities. (There are still some limited exceptions, such as when the journalist himself is under investigation for committing a crime, is an agent of a foreign power, or when disclosure is necessary to prevent imminent risk of death or serious bodily harm.) These are the updated guidelines about which Judge Faruqui was inquiring in the Shroyer case.

Is Shroyer a Journalist?

The DOJ media guidelines have been around for decades but have never defined who qualifies as a journalist under those guidelines. The governing regulations associated with those guidelines provide that whether someone is a member of the “news media” engaged in “newsgathering activities” must be determined on a case-by-case basis – but provide no guidance on how to make that determination. So is Infowars engaged in journalism, and is Shroyer a journalist?

Unlike professions such as law or medicine, which also enjoy certain legal privileges, there are no particular educational or licensing requirements to help define who is a journalist. In one sense, journalism is more of a process than a profession. Merriam-Webster defines journalism as “the collection and editing of news for presentation to the public.”  This could include anyone from a reporter for a national newspaper to a pajama-clad blogger working from home. The First Amendment’s protections apply equally to all such speakers and do not depend on the popularity of the views being expressed.

Fifty years ago, when media consisted primarily of newspapers, magazines, and the three major television networks, the Supreme Court observed that attempting to define who is a journalist for purposes of a legal privilege would be a “questionable procedure” that would “present practical and conceptual difficulties of a high order.” The rise of the Internet and the explosive growth of the media universe in the decades since have made that task exponentially more difficult. Now anyone with a cell phone can potentially disseminate information to millions of people and claim to be engaged in citizen journalism.

For years, efforts to enact a federal reporter’s privilege statute in Congress have foundered, at least in part, over the problem of defining who is a “journalist” entitled to invoke the privilege. Any such definition necessarily puts the government in a position of deciding which First Amendment speakers are “real” journalists deserving of special legal protections – a dubious Constitutional exercise. Even some in the media have opposed the idea, arguing that it amounts to allowing the government to license journalists.

One proposed solution is to limit the definition of journalists to those who make a substantial portion of their livelihood by gathering and disseminating news to the public. But that has problems as well. Such a definition tends to favor large, established media organizations and their staff over small, independent bloggers and other upstarts who may work for little or no money but often break major stories. And if the purpose of a privilege is to increase the flow of information to the public, it doesn’t make much sense to shield the communications of a reporter for a small local paper with a few hundred readers but not those of an independent blogger with a readership in the millions.

Shroyer allegedly participated in the riot, but at the same time was broadcasting information concerning what was happening to Infowars’ substantial audience. That portion of his activities, at least, would seem to qualify as journalism. But if Shroyer broadcasting live scenes from the Capitol qualifies, how about an individual blogger who attended and posted scenes on Facebook live or on her own blog? That person, too, is providing information to the public – the essence of journalism. Should the blogger also be shielded from investigation by the DOJ policy? Should subpoenaing the Facebook posts to further the investigation of the riot now be off-limits?

Lawyers love “slippery slope” arguments, and sometimes the dilemmas they pose are overstated. But defining who qualifies as a journalist and who doesn’t is a real problem with significant constitutional implications – at least if you are talking about granting special legal privileges to journalists that other First Amendment speakers do not enjoy.

What’s At Stake

Journalists can’t commit crimes in the course of reporting and claim they are immune. A reporter cannot, for example, break into someone’s office to steal documents and then defend herself by claiming she were working on a story. Whether or not Shroyer is a journalist is not going to determine whether he can be prosecuted. Judge Faruqui recognized that when he signed the arrest warrant even while questioning whether Shroyer was a member of the media. But Shroyer’s case does highlight the minefields for law enforcement in this area.

In the Internet age, the number of people who can credibly call themselves journalists, or say they are engaged in gathering news for delivery to the public, has grown dramatically. A policy that declares the records of any such person to be off limits has the potential to put a great deal of information outside the reach of law enforcement. That could severely hamper efforts to investigate not only major crimes like the Capitol riot but more everyday incidents as well.

It’s one thing if this is just an internal DOJ policy. That leaves the Justice Department free to investigate cases like Shroyer’s when it determines the policy does not apply – even if the occasional judge Faruqui improperly tries to look over prosecutors’ shoulders. But when announcing the updated guidelines, Garland also said DOJ would support Congressional efforts to enact a federal reporter’s privilege statute. If that happens, then a whole new generation of Internet “journalists” like Shroyer will routinely will invoke that legal privilege to resist requests for information, fight subpoenas, and seek to thwart prosecutions.

DOJ should be careful what it wishes for. By endorsing federal legislation that prohibits seeking information from all those engaged in “newsgathering,” DOJ would hand a weapon to defendants like Shroyer who seek to shield their criminal activities. Congress should think twice before putting the force of federal law behind such a weapon.

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The Julian Assange Indictment and Freedom of the Press

Last month the Justice Department announced a superseding indictment of Julian Assange, the founder of Wikileaks, charging him with multiple violations of the Espionage Act for soliciting and disclosing classified materials. The case has raised concerns over whether the government might apply the same prosecution theories to mainstream journalists who obtain and publish classified information. Although prosecutors are unlikely to go there, the Assange indictment highlights how much we rely on prosecutorial discretion to contain the sweeping and potentially troubling reach of certain criminal statutes. In an age where faith in the sound exercise of that discretion is eroding, prosecutors simply saying “we wouldn’t do that” may cease to be a satisfactory answer.

Julian Assange

Julian Assange

The Assange Indictment

In 2010 Julian Assange received hundreds of thousands of classified documents from Chelsea Manning, then known as Bradley Manning, who worked as an intelligence analyst for the army. Manning unlawfully sent Assange materials related to the U.S. wars in Iraq and Afghanistan and the detention facility at Guantanamo Bay, as well as thousands of classified State Department cables. Assange released the documents on Wikileaks during 2010 and 2011. It was one of the largest breaches of classified information in U.S. history.

In 2013 Manning was convicted of multiple felonies, including espionage. It appeared Assange would not be prosecuted. But this past April the Justice Department unveiled a sealed indictment charging Assange based on his dealings with Manning. Initially Assange was charged only with conspiracy to violate the Computer Fraud and Abuse Act, for helping Manning try to crack a computer password in order to hack into additional classified files. That effort was unsuccessful, but Assange was charged with conspiracy for taking part in the attempted hacking with Manning.

That initial indictment of Assange generally met with cautious approval from the media because DOJ had not charged him for obtaining or publishing any of the leaked materials. But on May 23, the Justice Department returned a superseding indictment. The new 18-count indictment includes multiple charges that Assange violated the Espionage Act by encouraging Manning to obtain classified information and leak it to Assange. It also charges Assange with three Espionage Act violations for publishing classified materials that revealed the identities of confidential sources who had helped the United States, including Afghans, Iraqis, journalists, human rights advocates, and religious leaders. The government alleges that by publishing that information, Assange knowingly placed those sources in grave danger.

The superseding indictment has caused great concern in the journalism community. National security reporters routinely receive and publish classified information, and may encourage sources to provide them with that information. What would prevent the Justice Department from applying the same legal theories used in the Assange case to prosecute a more mainstream journalist at the Washington Post or New York Times? The answer may be: legally, not much.

The Espionage Act

The Espionage Act, 18 U.S.C. 793, is a World War I-era law that prohibits obtaining or disclosing national security information with the intent or reason to believe it could be used to harm the United States or benefit a foreign nation. Several sections of the statute apply to those who are authorized to have the information but then improperly disclose it to others. These are the sections that may be used to prosecute those who leak classified information to a reporter. Most of the charges against Assange allege that he violated these sections by aiding and abetting or conspiring with Manning to have her leak the information to Assange.

Section 793(e) of the Act applies to those who are not otherwise authorized to have the information but obtain it and then transmit or communicate it to others also not authorized to have it. This is the section that potentially could apply to a journalist who receives a leak of classified information and then publishes it so others can read it. Assange is charged under this section for publishing only the materials that revealed the identities of confidential intelligence sources. He is not charged for publishing any of the hundreds of thousands of other documents he received from Manning and posted on Wikileaks.

The Espionage Act and the Press

Prior to the Assange case, the government had never prosecuted someone who at least claimed to be a journalist for publishing classified information received from a source. But the possible application of the Espionage Act to such a journalist has always been lurking in the background.

The concerns raised by the Assange indictment should be placed in the historical context of battles between the press and the executive branch that began escalating during the Obama Administration. The Obama Justice Department significantly expanded the use of the Espionage Act to prosecute leakers of national security information. You often hear that the Obama administration pursued more leak prosecutions than every prior administration combined. That’s true, but it was still only eight prosecutions, or about one a year. Even this relatively modest pace of cases resulted in blistering attacks from the media, which claimed the administration was engaging in a “war on the press” by trying to silence leakers.

There was arguably a technological rationale for the Obama administration’s change in policy. There have always been leaks of classified information to the press. But in the Watergate era, for example, if a reporter received classified information he or she generally would do some work to verify it. The reporter would also call government officials about the information and request comment. That at least gave officials the opportunity to try to persuade the reporter not to publish the information or to delay publication because it would jeopardize national security. Historically there have been times when the mainstream press honored such requests.

With the rise of the Internet, those safety valves have been largely obliterated. Now there are many websites and individuals who consider themselves journalists who are happy to take leaked information and just throw it up on their website. That’s what Assange did with the materials he received from Manning, as well as with the stolen Democratic emails and documents he received from Russian hackers during the 2016 presidential election. It made some sense for the Obama administration to try to plug serious leaks by cracking down on leakers themselves. In the age of Wikileaks, the only opportunity to prevent potentially damaging information from being immediately released worldwide, to friends and enemies alike, is to prevent it from ever being leaked in the first place.

Risen? Rosen? The Cases of the Two James

Leak prosecutions in the Obama years were brought only against the leakers, not against journalists. But they still caused considerable tension between the administration and the journalism community. For example, prosecutors had a protracted legal and public relations battle with New York Times reporter James Risen. Former CIA agent Jeffrey Sterling was prosecuted under the Espionage Act for leaking information to Risen that showed up in his book, State of War. Prosecutors wanted Risen to testify that Sterling was his source, and Risen refused. After a three-year battle, prosecutors obtained a court order that Risen had no privilege to protect his source and could be compelled to testify. However, faced with the prospect that Risen would refuse and force the government to have him jailed for contempt, the prosecutors blinked. They decided not to call Risen, and convicted Sterling at trial without Risen’s testimony. Risen was never criminally charged or forced to testify, but condemned Obama as the “greatest enemy to press freedom in a generation.”

But probably the most notorious incident involving the press during the Obama years was the 2010 prosecution of State Department analyst Stephen Kim. Kim was indicted for leaking information about North Korea’s nuclear program to Fox News reporter James Rosen. Prosecutors later obtained a search warrant for Rosen’s email account to look for communications with Kim. In the search warrant affidavit they characterized Rosen as a criminal co-conspirator or aider and abettor for encouraging Kim to leak the classified information to him. Legally this description was completely accurate, and Rosen was not prosecuted. But characterizing a journalist as a criminal co-conspirator in a search warrant affidavit caused a huge controversy and is still repeatedly cited as evidence that the Obama administration was hostile to the press.

According to news reports, the Obama administration also considered prosecuting Assange for his work with Manning but ultimately declined, believing the case would come too close to treading on freedom of the press. But the Trump administration revisited that decision. The legal theories used to prosecute Assange are largely the same as those contained in the Rosen search warrant: that he aided and abetted or conspired with the leaker who violated the law by disclosing the classified information. But the Assange indictment goes one step further by also charging Assange based on publishing a portion of the information, not just receiving it.

Meanwhile, the Trump administration has further accelerated the pursuit of leakers. In 2017, Attorney General Sessions announced the Justice Department had tripled the number of leak investigations.  When announcing the Assange indictment, DOJ officials said they have brought four leak prosecutions in two years, double Obama’s pace.

Is Assange a Journalist? That’s the Wrong Question

When announcing the Assange indictment, DOJ officials said they don’t consider Assange a journalist. Much of the commentary about the case suggests it should not be worrisome because Assange is not a true journalist. But whether or not he’s a journalist is really the wrong question. The First Amendment does not refer to “journalists” in the protections it provides for free speech and a free press. And the Supreme Court has made it clear that the First Amendment applies equally to the New York Times and to a pajama-clad blogger writing in his basement.

Defining who is a “journalist” is a thorny, and perhaps constitutionally insurmountable, problem. For years there have been efforts on Capitol Hill to pass a reporter’s shield law that would protect journalists from being compelled to identify their sources, at least in some cases. But those efforts have always stalled, due at least in part to the difficulty of defining who is a “journalist” entitled to the protection of the law.

Nearly fifty years ago, in the landmark case of Branzburg v. Hayes, the Supreme Court held that the Constitution does not create a reporter’s privilege. At the time, the Court noted that trying to define who is a “newsman” worthy of any such privilege “would present practical and conceptual difficulties of a high order” and would be a “questionable procedure.” That was at a time when the news media consisted largely of local newspapers, radio, and three television networks. In the age of the Internet, social media, and citizen journalism, those difficulties are exponentially greater. A definition necessarily excludes someone and puts the government in the position of deciding who it deems a “real” journalist worthy of a special legal privilege. That process itself raises grave First Amendment concerns.

There are certainly ways in which Assange differs dramatically from a mainstream journalist. He generally just dumps leaked materials on the Internet with no screening, verification, or reporting. He acts more like an agent of a hostile foreign power than a reporter. Most of his activities seem worthy of little sympathy. As the Assistant Attorney General said when announcing the Assange indictment, no responsible person, whether or not a journalist, would disclose the names of confidential intelligence sources in a war zone, knowingly exposing them to grave danger.

But the issue is not whether Assange is a journalist or whether his behavior is reprehensible. It’s whether the legal theories used to prosecute Assange also could be employed to prosecute a mainstream journalist, and thus whether the Assange indictment creates a potentially dangerous precedent. The answer appears to be yes.

The Tension Between the Press and the Government

There has always been a healthy tension between the press and the government. The government tries to keep some secrets. Most would agree that it tries to keep far too many and that it classifies too much information. Sometimes it tries to keep information secret not because its release would really damage national security but simply because it would be embarrassing or politically damaging.

Our robust free press and investigative journalism have always played a vital role in fighting excessive government secrecy and ferreting out important information. Scandals such as Watergate and the government excesses during the Iraq war only came to light through the efforts of dogged journalists. In many such cases that work involves the journalists receiving, and reporting on, leaked classified information.

On the other hand, almost all would agree there are some secrets the government should be able to keep. Leaks of the most sensitive military and intelligence information could genuinely harm our national interests or put those serving our country in harm’s way. And if we agree the government must be able to keep some secrets, then we should be able to agree that in appropriate cases the government may prosecute those who illegally disclose such vital information and try to deter others from doing so.

It’s also clear there can be no absolute immunity for journalists from criminal prosecution related to their work. To take an extreme example, a journalist could not hire a burglar to break into an office to steal confidential files, publish them, and then claim immunity from prosecution based on freedom of the press. If Assange had obtained classified information and hand-delivered to agents of the Taliban, it seems clear that he could be prosecuted for espionage. Why should the result be different because he chose to deliver the materials by posting them on the Internet?

The Role of Prosecutorial Discretion

In the end, these cases are all about line drawing. An investigative journalist at a mainstream newspaper regularly receives classified material. He or she may request such materials from a source, even try to cajole the source into obtaining more such materials, directly or subtly. At some point such encouragement or active participation could cross the line into soliciting criminal activity. What prevents such cases from being charged, at least up to this point, is respect for the role of the press and the sound exercise of prosecutorial discretion.

Government officials went out of their way to emphasize this when announcing the Assange indictment. They noted that prosecutorial decisions in each case have to be evaluated on their specific facts, and that mainstream journalism has nothing to fear from the Assange indictment. But the legal theories are there, and always have been.

This really isn’t that surprising. Many criminal statutes contain sweeping prohibitions that could potentially apply to a given case but prosecutors exercise their discretion not to pursue it. In particular, prosecutors traditionally have respected the role of the Fourth Estate. For example, although (as the Risen and Rosen cases demonstrated) journalists have no legal privilege to refuse to reveal their sources in federal cases or to shield their communications in general, DOJ has voluntary internal guidelines to ensure that seeking information from a reporter will be extremely rare and will require approval at the highest levels. This respect for the role of the press is part of the healthy push and pull between the press and the government that has always existed.

It’s probably true the Trump administration will not seek to expand the theories used against Assange to prosecute traditional journalists. Certainly there would be a huge outcry, even from the president’s friends in the conservative media. And there would be substantial constitutional defenses to any such case. This was not a routine leak, but one of the largest security breaches in U.S. history. And however we define journalism, most of Assange’s actions stray far from that concept.

But reliance on prosecutorial discretion requires trust that discretion will be exercised dispassionately, with some wisdom, humility, and historical perspective. Considering this president routinely refers to the press as the enemy of the American people and accuses the press of treason, you can’t blame journalists for being a little nervous.

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