Wisconsin Department of Revenue v. Midwestern Gas Transmission Co.

How later courts describe this case

• recognizing that majority of Supreme Court found no First Amendment privilege
• relying on Branzburg in holding that “no weighing or balancing of societal interests” is required to determine that a journalist has no privilege to withhold information from a grand jury
• abandoning holding of Mitchell v. Laird, 488 F.2d 611, 614 (D.C.Cir.1973
• labor dispute involved; picketing and sympathy strike not enjoinable because non-struck railroad has common interest with struck railroad by virtue of railroads' participation in strike insurance plan
• important interest of press in confidentiality of sources, though not constitutional, must be weighed against criminal defendant’s constitutional right to a fair trial
• labor dispute involved; picketing and sympathy strike not enjoinable because nonstruck railroad has common interest with struck railroad by virtue of railroads’ participation in strike insurance plan
• sixth amendment right to cross-examine overrides state reporter’s shield law
• refused to apply first-amendment privilege in criminal investigation