Reporter's privilege in the United States (also journalist's privilege, newsman's privilege, or press privilege), is a "reporter's protection under constitutional or statutory law, from being compelled to testify about confidential information or sources." It may be described in the US as the qualified (limited) First Amendment or statutory right many jurisdictions have given to journalists in protecting their confidential sources from discovery. The First, Second, Third, Fifth, Eighth, Ninth, Tenth, Eleventh, and D.C. Circuits have all held that a qualified reporter's privilege exists. In the recent case of U.S. v. Sterling, the Fourth expressly denied a reporter's privilege exists under Branzburg. Furthermore, forty-nine states and the District of Columbia have enacted statutes called shield laws protecting journalists' anonymous sources. United States Department of Justice guidelines (United States) The United States Department of Justice created self-imposed guidelines intended to protect the news media by regulating the use of subpoenas against the press. These guidelines state that the government "should have made all reasonable attempts to obtain the information from alternative, non-media sources” before considering issuing a subpoena to a member of the news media. Furthermore, the guidelines require that federal prosecutors negotiate with the press, explaining the specific needs of the case. Before any subpoena may be issued, the attorney general must approve the issuance. The attorney general’s review for a subpoena to a member of the news media shall be based on the following criteria: In criminal cases, there should be reasonable grounds to believe, based on information obtained from non-media sources, that a crime has occurred, and that the information sought is essential to a successful investigation—particularly with reference to directly establishing guilt or innocence. The subpoena should not be used to obtain peripheral, nonessential, or speculative information. In civil cases there should be reasonable grounds, based on non-media sources, to believe that the information sought is essential to the successful completion of the litigation in a case of substantial importance. The subpoena should not be used to obtain peripheral, nonessential, or speculative information. The government should have unsuccessfully attempted to obtain the information from alternative non-media sources. The use of subpoenas to members of the news media should, except under exigent circumstances, be limited to the verification of published information and to such surrounding circumstances as relate to the accuracy of the published information. Even subpoena authorization requests for publicly disclosed information should be treated with care to