avoid claims of harassment. Subpoenas should, wherever possible, be directed at material information regarding a limited subject matter, should cover a reasonably limited period of time, and should avoid requiring production of a large volume of unpublished material. They should give reasonable and timely notice of the demand for documents. While these guidelines seem extremely protective of the press, they explicitly deny the creation of “any right or benefit, substantive or procedural, enforceable at law.” Nor does the policy have any substantive punishment for the federal government violations. If the federal prosecutors fail to obtain approval from the attorney general, the extent of the authorized punishment is “an administrative reprimand or other appropriate disciplinary action.” In fact, some courts have found that the guidelines “create no enforceable right.” Therefore, in circuits taking this approach, the news media have no right to appeal for enforcement of these policies before being compelled to testify. Judith Miller's attempted use of reporter's privilege The issue of a reporter's privilege came to the forefront of media attention in the 2005 case In re Miller, involving reporters Judith Miller and Matthew Cooper. Miller and Cooper were both served with grand jury subpoenas for testimony and information, including notes and documents pertaining to conversations with specific and all other official sources relating the Plame affair. Both refused to submit to the subpoenas, claiming a reporter’s privilege. The federal district court held both Miller and Cooper in civil contempt of court, and the United States Court of Appeals for the District of Columbia Circuit upheld the orders of contempt. Miller and Cooper, in their appeal to the appellate court pleaded several defenses including a First Amendment reporter’s privilege and a common law reporter’s privilege. The appellate court rejected both the First Amendment and common law claims for privilege. The court held Miller and Cooper in civil contempt of court and sentenced both to eighteen months of jail time. The sentence was stayed pending an appeal to the U.S. Supreme Court. However, the U.S. Supreme Court refused to hear the case. Judith Miller began serving the remaining four months of the original eighteen-month sentence on July 6, 2005. Matthew Cooper’s confidential source released him from their confidentiality agreement, so he chose to comply with the subpoena and has agreed to testify before the grand jury. Congressional proposals In 2004, two significant bills were introduced in the United States House