The Right of Journalists Not to Disclose Their Sources and the New Media

Stratilatis, Costas

doi:10.1007/978-3-319-64955-9_14

Costas Stratilatis⁵

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Abstract

This chapter deals with the issue of whether the right of journalists not to disclose their sources should be extended to protect the various ‘citizen journalists’ of the New Media. After expounding some jurisprudential attempts to confront this issue in the USA and after tracing the restrictive tendencies in the available instruments of the Council of Europe, this chapter examines and criticizes a recent attempt to escape this problem focusing on the ‘source’ rather than on the ‘journalist’. Returning back to the traditional context of the debate, in its last section, this chapter proposes an enlargement of the traditional concept of ‘journalist’ to provide protection to all persons who disseminate information to the public through the use of New Media, provided that these persons had the intent to do so (i.e. to disseminate information) already at the inception of the information-gathering process.

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Notes

1.
See in general Barendt (2005), pp. 435–441, and Sect. 4 of this chapter.
2.
For a comprehensive survey, see Banisar (2007). International law instruments include the Inter-American Declaration of Principles on Freedom of Expression (Principle 8), approved by the Inter-American Commission on Human Rights at its 108th regular sessions in October 2000; the Declaration of Principles on Freedom of Expression in Africa (Art. XV), approved by the African Commission on Human and Peoples’ Rights at its 32nd session in October 2002; and Recommendation (2000) 7 of the Committee of Ministers of the Council of Europe, to which reference shall be made in Sect. 3. Domestic legal protection is provided either through constitutional (see e.g. Art. 38.2 of the Constitution of Portugal) or, most commonly, through legislative provisions (see e.g. the French Loi n^o 2010-1 du 4 janvier 2010 relative à la protection du secret des sources des journalistes, also section 10 of the Contempt of Court Act 1981 in the UK).
3.
ECtHR (Grand Chamber), Goodwin v. the United Kingdom, App No 17488/90, 27 March 1996. All judgments of the ECtHR have been retrieved from the HUDOC database.
4.
Apart from the Goodwin v. the United Kingdom judgment, see also ECtHR (Grand Chamber), SanomaUitgevers B.V. v. the Netherlands, App No 38224/03, 14 September 2010, ECtHR, Voskuil v. the Netherlands, App No 64752/01, 22 November 2007; ECtHR, Financial Times Ltd and Other v. the United Kingdom, App No 821/03,15 December 2009; ECtHR, Telegraaf Media Nederland Landelijke Media B.V. and Others v. the Netherlands, App No 39315/06, 22 November 2012.
5.
See ECtHR, Roemen and Schmitt v. Luxembourg, App No 51772/99, 25 February 2003; ECtHR, Ernst and Others v. Belgium, App No 33400/96, 15 July 2003; ECtHR, Tillack v. Belgium, App No 20477/05, 27 November 2007; ECtHR, Martin and Others v. France, App No 30002/08, 12 April 2012; ECtHR, Ressiot and Others v. France, App No 15054/07 and 15066/07, 28 June 2012; ECtHR Saint-Paul Luxembourg S.A. v. Luxembourg, App No 26419/10, 18 April 2013; ECtHR, Nagla v. Latvia, App No 73469/10 16 July 2013; ECtHR, Görmüş and Others v. Turkey, App No 49085/07, 19 January 2016. Searches and seizure cases are sometimes examined under both Art. 10 and Art. 8 (respect for private life) ECHR.
6.
See ECtHR, Ressiot and Others v. France, also ECtHR (admissibility), Weber and Saravia v. Germany, App No 54934/00, 29 June 2006. In this latter case, the ECtHR held that surveillance of telecommunications constitutes a prima facie interference with protection of journalistic sources under Art. 10 ECHR (par. 144–146), but it rejected the applicants’ complaint because the relevant provisions of German law contained adequate safeguards (par. 150–153).
7.
See on this particularly ECtHR (Grand Chamber), SanomaUitgevers B.V. v. the Netherlands., par. 65–72, with extended references to the relevant findings of earlier judgments, also ECtHR, Telegraaf MediaNederland Landelijke Media B.V. and Others v. the Netherlands,, par. 86–87.
8.
See e.g. ECtHR (Grand Chamber), Goodwin v. the United Kingdom, par. 81, ECtHR, Telegraaf Media Nederland Landelijke Media B.V. and Others v. the Netherlands, par. 89–91, ECtHR (adm.), Weber and Saraviav. Germany, par. 92–95.
9.
See e.g. ECtHR (Grand Chamber), Sanoma Uitgevers B.V. v. the Netherlands, par. 90–98, ECtHR, Telegraaf Media Nederland Landelijke Media B.V. and Others v. the Netherlands, par. 99–101; Nagla v. Latvia, par. 87–90.
10.
See e.g. ECtHR, Roemen and Schmitt v. Luxembourg, par. 56; Ernst and Others v. Belgium, par. 102; Martin and Others v. France, par. 86; Voskuil v. the Netherlands, par. 58-62; Saint-PaulLuxembourg S.A. v. Luxembourg, par. 44.
11.
See e.g. ECtHR (Grand Chamber), Goodwin v. the United Kingdom, par. 39-40, ECtHR, Tillack v. Belgium, par. 60–67; Naglav. Latvia, par. 94–102.
12.
Branzburg v. Hayes 408 U.S. 665 (1972). For a detailed presentation of the litigation in Branzburg, see among others Andersen Jones (2013), pp. 1231–1237.
13.
Such refusal has recently been affirmed in the Risen and Sterling case. See Liptak (2014), United States of America v. Sterling, F.3d 482 (4th Cir. 2013), and Konarski (2014–2015), with a scholarly discussion to the effect that the Supreme Court should revisit Branzburg in view of the Risen and Sterling case. The latter concerned the refusal of Risen, a national security reporter of New York Times, to reveal the identity of Sterling, a former CIA employee, as his source for writing articles and a book on the plans and activities of CIA. Another famous case in which federal courts refused protection under the privilege was In re Grand Jury Subpoena, Judith Miller, 397 F.3d 964 (D.C. Cir. 2005).
14.
For presentation see among others Campagnolo (2002–2003), pp. 478–491, Fargo (2005–2006), pp. 1078–1102, Dalglish and Murray (2006–2007), Ugland (2010), pp. 17–34, Rosenbaum (2013–2014), pp. 1439–1446. For the assertion of the privilege under Federal Rule of Evidence 501, see Nestler (2005–2006), Papandrea (2007), pp. 559–564; but see also Campagnolo (2002–2003). The Federal Courts, which recognize a journalist’s privilege under the First Amendment, qualify it following some variation of the three-factor test that the dissenting opinion of Justice Stewart in Branzburg had proposed. According to this test, ‘the government must (1) show that there is probable cause to believe that the newsman has information that is clearly relevant to a specific probable violation of law; (2) demonstrate that the information sought cannot be obtained by alternative means less destructive of First Amendment rights; and (3) demonstrate a compelling and overriding interest in the information’. See Branzburg v. Hayes, 408 U.S. 665, 743 (1972).
15.
For a map with links to the relevant provisions and jurisprudence in each state, see the digital Compendium of Reporter’s Privilege (2016). See also the comprehensive surveys of Martin and Fargo (2013), pp. 53–65, and Papandrea (2007), pp. 545–551, 564–567.
16.
See e.g. Stone (2005–2006), Alonzo (2005–2006), pp. 778–779, Gomsak (2006–2007), Turner (2011), Martin and Fargo (2013), pp. 93–94, Rosenbaum (2013–2014), Tursi (2014), Harris (2013–2014), pp. 1822–1824. However, see also Eliason (2006–2007) (arguing that a federal shield law would not alleviate the problem and that it would anyway provide for an overly qualified privilege, not suitable to carry out its assumed function), Castiglione (2007) (offering a ‘structuralist’ critique of the privilege and expressing doubts with reference to the risks of its legislative entrenchment). Attempts to pass a federal shield law were intensified once more after the refusal of the Supreme Court to hear the Risen case; see Gierhart (2014).
17.
See e.g. Stone (2005–2006), pp. 43, 45, Rosenbaum (2013–2014), p. 1458, Tursi (2014), pp. 224 et seq. For an empirical study on the effect of the absence of a federal shield law on the amount of subpoenas received by journalists and by media organizations, see Andersen Jones (2008–2009).
18.
See in general Wall (2012), Allan and Thorsen (2009), and for the manifesto of grassroots online journalism Gillmor (2004). The terms ‘citizen journalism’ and ‘citizen journalists’ are commonly used by legal scholars discussing the problem of the journalist’s privilege; see e.g. Papandrea (2007), Turner (2011–2012), Rosenbaum (2013–2014).
19.
Wikileaks is a media-organization that specializes in on-line publication of “censored or otherwise restricted official materials” of public interest. See https://wikileaks.org/What-is-Wikileaks.html. Accessed 7 May 2017.
20.
See Martin and Fargo (2013), p. 65, Papandrea (2007), pp. 564–565.
21.
See Compendium of Reporter’s Privilege (2016), Martin and Fargo (2013), pp. 53–65, Papandrea (2007), pp. 564–567.
22.
Loi du 29 juillet 1881 sur la liberté de la presse, Art. 2, as amended by Loi n^o 2010-1 du 4 janvier 2010 relative à la protection du secret des sources des journalistes, Art. 1, Free translation, Accessed 23 Nov. 2016.
23.
See among others Alonzo (2005–2006), Papandrea (2007), Toland (2009), Kirtley (2009–2010), Turner (2011–2012), Clark and Barnette (2012), Martin and Fargo (2013), Andersen Jones (2013), pp. 1270–1281, Rosenbaum (2013–2014), Harris (2013–2014).
24.
O’Grady v. Superior Court, 44 Cal. Rptr. 3d 72 (Cal. Ct. App. 2006).
25.
Ibid at 91–92.
26.
Ibid at 99.
27.
Ibid at 99.
28.
Ibid at 99.
29.
Ibid. at 100.
30.
Ibid. at 97.
31.
Ibid. at 100–105.
32.
Ibid. at 103.
33.
Ibid. at 102.
34.
Ibid. at 104–105.
35.
Johns-Byrne Company v. TechnoBuffalo LLC, et al., Order, Case No. 2011 L 009161 (Ill. Cir. Ct. July 13, 2012),http://www.dmlp.org/threats/johns-byrne-company-v-technobuffalo. Accessed 15 May 2016.
36.
Ibid. at 5–6.
37.
999 A.2d 184 (N.H. 2010).
38.
Ibid. at 189.
39.
Ibid. at 189.
40.
Ibid. at 189.
41.
Ibid. at 190–191, citing Bruno & Stillman, Inc. v. Globe Newspaper Co., 633 F.2d 583, 594.
42.
Too Much Media v. Hale 20 A.3d 364 (N.J. 2011).
43.
Ibid. at 369 et seq.
44.
The Court itself took the privilege to be absolute in civil defamation and libel cases, ibid. at 383. We believe that this played a role to the Court’s hesitant stance as regards the expansion of the privilege to the activity of posting extended commentaries (indeed, in the form of articles) to the message board of another person.
45.
The Court assessed the shield law as one ‘among the broadest in the nation’, ibid. at 375.
46.
Ibid. at 376. According to the Court’s interpretation of the relevant statutory provisions, such nexus need not be taken as equivalent to being employed by or to having a direct tie to a traditional medium.
47.
Ibid. at 377–378.
48.
Ibid. at 378.
49.
Ibid. at 378–379.
50.
Ibid. at 379. At this point, the Court distinguished Too Much Media from O’Grady, based on the distinction of the latter between news-oriented websites and the deposit of information or opinion by casual visitors to open fora. Ibid. at 379–380.
51.
Ibid. at 380 et seq.
52.
Ibid. at 373–374, 380–381.
53.
Ibid. at 380, quoting In re Madden, 151 F.3d 125, 131 (3d Cir. 1998).
54.
See In re Madden, at 129–130, Schoen v. Schoen, 5 F.3d 1289, 1293 (9th Cir. 1993), von Bulow v. von Bulow, 811 F.2d 136, 142–143 (2d Cir. 1987), retrieved from the LexisNexis database.
55.
Too Much Media v. Hale 20 A.3d 364, 383 (N.J. 2011).
56.
Ibid., at 383.
57.
Martin and Fargo (2013), p. 85.
58.
Ibid, p. 93.
59.
Ibid, p. 92.
60.
Ibid, pp. 89–93.
61.
Ibid, p. 93.
62.
Berger (2002–2003), pp. 1406–1411.
63.
Ibid, pp. 1411–1416.
64.
Papandrea (2007), p. 583.
65.
Ibid, p. 583.
66.
Ibid, pp. 519–520.
67.
Ibid, p. 584.
68.
Ibid, p. 584.
69.
Ibid, p. 585.
70.
Ibid, p. 585.
71.
See Harris (2013–2014), p. 1847, referring to Davidson and Herrera (2011–2012), p. 1312. In a more recent publication, Papandrea (2011–2012, p. 129) argued that ‘[t]he dissemination of information by nongovernment actors should be punishable only if the offender acted with the intent to harm the United States or with reckless indifference to such harm. This sort of intent standard would provide protection for all responsible publishers acting in good faith, no matter who they are or what medium they use for communication’.
72.
See among others Peters (2010–2011), Davidson and Herrera (2011–2012), Clark and Barnette (2012), Harris (2013–2014). For a more general account of the legal problems and answers regarding Wikileaks under the First Amendment, see Benkler (2011).
73.
See the cases referred to in n54 above, and Cusumano v. Microsoft, 162 F.3d 708 (1st Cir. 1998). The relevant criteria have been presented in n53 above.
74.
Peters (2010–2011), pp. 676–683.
75.
Ibid, p. 679.
76.
Ibid, pp. 679–680.
77.
Ibid, p. 681.
78.
Ibid, p. 683.
79.
Clark and Barnette (2012), pp. 178–179.
80.
The term ‘watchdog function’ is a classic one in the jurisprudence and in the public debate which is related with the First Amendment and with freedom of the press in the USA. The term generally indicates the crucial role of the media in checking the Government, either directly (e.g. through investigative journalism, through interviewing of public officials, through fact-checking of their statements etc.) or indirectly (through creating an informed public).
81.
Benkler (2011), pp. 359–362.
82.
Ibid, pp. 361–362.
83.
Ibid, p. 362.
84.
Harris (2013–2014), pp. 1838–1840 (Harris’ analysis refers to Cusumano v. Microsoft, 162 F.3d 708 (1st Circ. 1998), Summit Tec., Inc. v. Healthcare Capital Grp., Inc., 141 F.R.D. 381 (D. Mass. 1992), Blum v. Schlegel, 150 F.R.D. 42 (W.D.N.Y. 1993), U.S. Commodity Futures Trading Comm’n v. McGraw-Hill Cos., 390 F. Supp. 2d 27 (D.D.C 2005)).
85.
Ibid, p. 1840.
86.
In fact, none of the cases that were referred to at the beginning of this chapter questioned the quality of the person bringing the complaint as a journalist. Apart from our thorough research into the HUDOC database, our conviction is also based on the fact that there is no relevant indication in the recent factsheet of the Court on the protection of journalistic sources (European Court of Human Rights 2016). In a 2012 judgment, the Grand Chamber did not grant protection under its Goodwin v. the United Kingdom jurisprudence to a university professor who had refused to provide access to his research material to other researchers. See ECtHR (Grand Chamber), Gillberg v. Sweden, App No.41723/06, 3 April 2012, par. 95. The thoughts of the Court in Gillberg v. Sweden cannot provide guidance as regards a future treatment of the problem at hand, as the Court considered that the relevant information (i.e. the research material) already belonged to the public domain, and that refusal to grant access to it constituted a hindrance to the free exchange of opinions and ideas.
87.
Recommendation (2000) 7 of the Committee of Ministers on the right of journalists not to disclose their sources. Adopted on 8 March 2000 at the 701st meeting of the Ministers’ Deputies, available via the official website of the Council of Europe.
88.
Emphasis added.
89.
A similar qualification appeared in the 2011 bill, which unsuccessfully attempted to pass a federal ‘shield law’ provision through the Congress in the USA. This provision would protect only persons who ‘regularly’ engage in several news- or information-gathering and dissemination activities ‘for a substantial portion of … [their] livelihood or for substantial financial gain’; see Rosenbaum (2013–2014), p. 1450.
90.
Emphasis added.
91.
Emphasis added.
92.
Emphasis added.
93.
Emphasis added.
94.
Emphasis added.
95.
Recommendation 1950 (2011) of the Parliamentary Assembly of the Council of Europe on the protection of journalists’ sources. Adopted by the Assembly on 25 January 2011 (4th Sitting), available via the official website of the Council of Europe.
96.
Par. 11 of the 2011 Recommendation on the protection of journalists’ sources.
97.
Emphasis added.
98.
Emphasis added.
99.
Par. 15 of the 2011 Recommendation on the protection of journalists’ sources.
100.
Recommendation (2011) 7 of the Committee of Ministers on a new notion of media. Adopted on 21 September 2011 at the 1121st meeting of the Ministers’ Deputies, available via the official website of the Council of Europe.
101.
Par. 7 of the 2011 Recommendation on a new notion of media.
102.
Par. 7 of the 2011 Recommendation on a new notion of media.
103.
Par. 11 of the Appendix of the 2011 Recommendation on a new notion of media.
104.
Par. 11 of the Appendix of the 2011 Recommendation on a new notion of media.
105.
Par. 73 of the Appendix of the 2011 Recommendation on a new notion of media. Protection of sources is also mentioned at par. 42 of the Appendix, and it is listed among the rights, privileges and prerogatives whose assertion ‘can be very revealing’ as an indicator of meeting criterion 4: ‘professional standards’.
106.
Par. 71 of the Appendix of the 2011 Recommendation on a new notion of media. Bloggers are also mentioned in the section of Part I of the Appendix, which specifies the criterion of ‘professional standards’. There (par. 41) it is stipulated that bloggers ‘should only be considered media if they fulfil the criteria to a sufficient degree’.
107.
In the Appendix to Recommendation (2000) 7 it is pointed out (par. 37–41) that the most important aims which may justify disclosure of journalist’s sources are protection of human life, prevention of major crime and defense of a person accused or convicted of having committed a major crime.
108.
See Branzburg v. Hayes, 408 U.S. 665, 682–693, 701–702 (emphasizing the significance of testifying before a grand jury for crime investigation), 703–704 (stressing the conceptual difficulties which are related with defining a ‘reporter’ for a hypothetical privilege under the First Amendment), 705 (expressing concerns with regard to the fact that ‘[t]he informative function asserted by representatives of the organized press in the present cases is also performed by lecturers, political pollsters, novelists, academic researchers, and dramatists’, so that all these persons could be ‘silenced’ before grand juries) (1972).
109.
For Branzburg’s and consequent cases’ focus on the reporter, see Andersen Jones (2013), pp. 1235–1237, 1239–1242.
110.
See among others Ugland (2010) (distinguishing between policy- and principle-based approaches), Nestler (2005–2006), esp. pp. 206–212 (offering a survey of different justifications of the privilege on First Amendment grounds), Andersen Jones (2013) and Stone (2005–2006) (to whose source-oriented approach we shall refer later on), Konarski (2014–2015) (endorsing a checks-and-balances-oriented approach).
111.
ECtHR, Goodwin v. the United Kingdom.
112.
See Branzburg v. Hayes, 408 U.S. 665, 713–725 (Justice Douglas, dissenting opinion, arguing for the constitutional recognition of the journalist’s privilege based on effective self-government arguments, among else), 725–752 (Justice Stewart, dissenting opinion, joined by Justices Brennan and Marshall, stressing the importance of a free press within a democratic society and advocating that non-recognition of the privilege under the First Amendment would undermine the news gathering and dissemination process, to the detriment of the relevant fundamental rights of the press) (1972).
113.
Andersen Jones (2013), p. 1243.
114.
See Andersen Jones (2013), pp. 1242–1244, Eliason (2006–2007), pp. 417–418; see also the ambivalent conclusions of the empirical research of Andersen Jones (2008–2009); cf. Ugland (2010) pp. 45–46: ‘The chilling effect on speech, the wariness of sources, the broader symbolic damage to the image of the press when it cooperates with government–none of these things is readily measurable, but they are no less real because of it’.
115.
Cf. Branzburg v. Hayes, 408 U.S. 665, 698–699 (1972).
116.
For the assertion of this right under the First Amendment in USA case-law, for its qualification and for its possible application to the confidential-source situation, see among others Andersen Jones (2013), pp. 1249–1270. In the 2012 Gillberg v. Sweden case, and after it re-examined its scarce case-law on the subject, the ECtHR did ‘not rule out that a negative right to freedom of expression is protected under Article 10 of the Convention’, but it also found ‘that the issue should be properly addressed in the circumstances of a given case’ (par. 86).
117.
Ibid.
118.
Stone (2005–2006), pp. 39–41, 50–51.
119.
Harris (2013–2014), pp. 1856–1846, 1849–1851.
120.
Stone (2005–2006), pp. 39–41.
121.
Ibid, p. 41.
122.
Ibid, p. 51.
123.
See Papandrea (2007), p. 582.
124.
Andersen Jones (2013), pp. 1238–1249.
125.
Ibid, pp. 1249–1259. The most important cases analyzed by Andersen Jones are Talley v. California, 362 U.S. 60 (1960), McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995), and Buckley v. Valeo, 424 U.S. 1 (1976).
126.
Ibid, p.1259 et seq.
127.
Emphasis added.
128.
Andersen Jones (2013), pp. 1264–1265.
129.
Ibid, p. 1261.
130.
Ibid, pp. 1262–1263, references omitted.
131.
The emphasis on the protection of this right fits well with the current trends towards increased protection of ‘whistleblowers’. See Recommendation CM/Rec (2014) 7 of the Committee of Ministers of the Council of Europe on the protection of whistleblowers, adopted on 30 April 2014 at the 1198th meeting of the Ministers’ Deputies, available via the official website of the Council of Europe. Adjustment of the protection of journalistic sources is mentioned at par. 37 of the Explanatory Memorandum, as one of the measures that states could take towards improving the legal protection of whistleblowers.
132.
This scenario presents third-party-standing implications, with which we cannot here be concerned. See, in the context of USA jurisprudence, Andersen Jones (2013), pp. 1266–1270, 1273–1277.
133.
See Andersen Jones (2013), pp. 1275–1277, where relevant references; cf. Kirtley (2009–2010), p. 1508 and passim.
134.
Cf. the discussion in Tursi (2014), pp. 224–229, and in Harris (2013–2014), pp. 1841–1842.
135.
Cf. Stone (2005–2006), p. 48, referring to the Supreme Court granting deference to a possible federal shield law.
136.
See e.g. the rich references in Turner (2011–2012), pp. 509–510, Alonzo (2005–2006), pp. 772–774, and Rosenbaum (2013–2014), pp. 1457–1458.
137.
Turner (2011–2012), pp. 510–511.
138.
Ibid, p. 510, note 47.
139.
Ibid, p. 511.
140.
Ibid, p. 511.
141.
Rosenbaum (2013–2014), p. 1457, referring to the SCOTUS blog’s accurate reporting on a Supreme Court’s ruling as compared with the relevant CNN’s inaccurate report.
142.
Ibid, pp. 1461–1462, Papandrea (2007), p. 576, Turner (2011–2012), pp. 514–515.
143.
See e.g. Berger (2002–2003), pp. 1410–1411, Papandrea (2007), p. 574, Martin and Fargo (2013), pp. 89, 91–92.
144.
Such a ‘similarity standard’ was used by the O’Grady judgment of the California Court of Appeal and by the Too Much Media judgment of the New Jersey Supreme Court, to which we referred above. The adoption of such a standard is promoted by Toland (2009), pp. 484 et seq., and by Turner (2011–2012), pp. 515–518, leaving out of protection casual posting to social media, chat rooms or other messaging platforms.
145.
See Rosenbaum (2013–2014), p. 1462.
146.
See Papandrea (2007), pp. 575–581.
147.
Rosenbaum (2013–2014), p. 1460, adopting the phrasing of a proposed federal shield law that did not manage to pass through the Congress in 2009. Federal Circuit Courts used the same standard to afford protection under the journalist’s privilege. See n 54 above.
148.
See Papandrea (2007), pp. 585–586. To be reminded, however, that Papandrea combines the expansive approach as regards the scope of the right with rather strict qualifications as regards its application. See Sect. 2.2 of this essay.
149.
Cf. Rosenbaum (2013–2014), pp. 1460–1461, requiring in addition that such an intent should actually be a ‘journalistic’ one, also requiring that ‘[t]his journalistic intent would need to be manifested outwardly to sources, as the information source would need to be aware that he was speaking to someone engaged in journalism, regardless of the platform used’. We believe that these additional requirements open the ‘back door’ to the restrictive tendencies which are related with the criteria that we dismissed above.

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University of Nicosia, 46 Makedonitissis Avenue, Engomi, Cyprus
Costas Stratilatis

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Costas Stratilatis
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Correspondence to Costas Stratilatis .

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Department of Law, University of Cyprus, Nicosia, Cyprus
Tatiana-Eleni Synodinou
School of Law, European University Campus, Nicosia, Cyprus
Philippe Jougleux
School of Law, European University Campus, Nicosia, Cyprus
Christiana Markou
School of Law, European University Campus, Nicosia, Cyprus
Thalia Prastitou

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Stratilatis, C. (2017). The Right of Journalists Not to Disclose Their Sources and the New Media. In: Synodinou, TE., Jougleux, P., Markou, C., Prastitou, T. (eds) EU Internet Law. Springer, Cham. https://doi.org/10.1007/978-3-319-64955-9_14

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DOI: https://doi.org/10.1007/978-3-319-64955-9_14
Published: 11 November 2017
Publisher Name: Springer, Cham
Print ISBN: 978-3-319-64954-2
Online ISBN: 978-3-319-64955-9
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