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“The protections of the 1st Amendment do not turn on whether the defendant was a trained journalist, formally affiliated with traditional news entities,” Judge Andrew D. Hurwitz wrote. Judge Hurwitz sat on a three-judge panel to hear the case at the United States 9th Circuit Court of Appeals."
http://www.jdjournal.com/2014/01/21/appeals-court-rules-blogger-protected-by-1st-amendment-rights/#