In Branzburg v. Hayes, the Supreme Court held that:

a) contempt of court is possible even if the contemptuous act occurs some distance from the courtroom; b) contempt citations violate the First Amendment when used to prevent media commentary, unless there is a clear and present danger to the administration of justice; c) reporters must always testify when ordered to do so by a judge; d) reporters must testify before federal grand juries, but there may be other times when reporter’s privilege exempts them from testifying; e) all of these.

D