"More recently, the Ninth Circuit recognized that “the protections of the First Amendment do not turn on whether the [party] was a trained journalist, formally affiliated with traditional news entities, engaged in conflict-of-interest disclosure, went beyond just assembling others’ writings, or tried to get both sides of a story.” Obsidian Financial Group, LLC v. Cox, 740 F.3d 1284, 1291 (9th Cir.), cert. denied, 134 S. Ct. 2680 (2014).
It pointed out that “a First Amendment distinction between the institutional press and other speakers is unworkable: ‘With the advent of the internet and the decline of print and broadcast media . . . the line between the media and others who wish to comment on political and social issues becomes far more blurred.’”
Id. at 1291 (quoting Citizens United v. Fed. Election Comm’n, 558, U.S. 310, 352 (2010)). As one court wrote in recognizing the constitutional rights of citizens to record police in public, developments in technology “make clear why the news-gathering protections of the First Amendment cannot turn on professional credentials or status.” Glik, 655 F.3d at 84. "
Source
https://www.aclupa.org/sites/default/files/field_documents/amicus_brief_of_rutherford_institute_-_103116_.pdf
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