Preventing Media Capture: Tactics and Strategies
Overview
Media capture—when authoritarian forces gain control over news and information systems—is a critical step in democratic backsliding. Unlike outright censorship, media capture is often gradual, using economic pressure, legal harassment, and ownership consolidation to transform independent journalism into regime propaganda. This document outlines tactics to recognize, resist, and prevent media capture.
Critical Context: Media capture typically precedes or accompanies other authoritarian moves. A free press is democracy’s early warning system and primary defense. Once media is captured, organizing resistance becomes exponentially harder.
Part II: Tactics to Prevent Media Capture
For Journalists and Media Workers
1. Economic Independence and Resilience
Diversify Revenue Streams:
- Membership/subscription models (reader-supported, not advertiser-dependent)
- Small-donor crowdfunding (many small donors vs. few large ones)
- Nonprofit structures (501(c)(3) status, foundation support)
- Cooperative ownership (worker-owned, community-owned)
- International funding (foreign foundations, global journalism funds)
- Events and training (conferences, workshops, educational programs)
Reduce Vulnerability:
- Minimize dependence on government advertising
- Avoid debt and financial leverage
- Build cash reserves for crisis periods
- Diversify ownership (no single owner to pressure)
- International corporate structure if needed
Examples of Resilient Models:
- ProPublica (nonprofit investigative journalism)
- The Guardian (trust ownership, reader support)
- De Correspondent (Netherlands, member-funded)
- Mediapart (France, subscriber-supported)
- The Marshall Project (nonprofit criminal justice reporting)
2. Legal Defense and Protection
Organizational Measures:
- Legal defense funds (pre-positioned resources)
- Pro bono legal networks (committed attorneys)
- Insurance (media liability, defamation coverage)
- International legal support (press freedom organizations)
- Rapid response legal teams (immediate representation)
Anti-SLAPP Strategies:
- Early dismissal motions
- Countersuits for malicious prosecution
- Public exposure of SLAPP tactics
- Legislative advocacy for anti-SLAPP laws
- Crowdfunded legal defense
Protective Legal Structures:
- Offshore servers and hosting
- International incorporation
- Shield laws and reporter’s privilege
- Source protection protocols
- Encryption and secure communications
Key Organizations:
- Reporters Committee for Freedom of the Press
- Committee to Protect Journalists
- Freedom of the Press Foundation
- PEN America
- Electronic Frontier Foundation
3. Physical and Digital Security
Personal Safety:
- Threat assessment and security planning
- Secure communications (Signal, encrypted email)
- Operational security training
- Safe houses and evacuation plans
- Family protection measures
- International relocation preparation
Digital Security:
- Encryption: End-to-end encrypted communications
- VPNs and Tor: Anonymous browsing and research
- Secure devices: Hardened laptops and phones
- Air-gapped systems: Sensitive work offline
- Password management: Strong, unique passwords
- Two-factor authentication: All accounts protected
- Regular security audits: Professional assessment
Source Protection:
- SecureDrop and encrypted submission systems
- Metadata scrubbing
- Anonymous communication channels
- Legal protection for confidential sources
- Compartmentalization of information
- Secure physical meetings
Newsroom Security:
- Physical security (access control, cameras)
- Secure communications infrastructure
- Regular security training
- Incident response plans
- Legal and technical support on call
4. Editorial Independence and Integrity
Structural Protections:
- Editorial independence clauses in ownership documents
- Firewall between business and editorial
- Editor hiring/firing requires board approval
- Transparent corrections and accountability
- Ethics codes and ombudsmen
- Public editor or reader representative
Professional Standards:
- Rigorous fact-checking and verification
- Multiple source requirements
- Document-based reporting
- Transparency about methods and sources
- Corrections and accountability
- Avoid access journalism and capture
Resist Self-Censorship:
- Explicit discussions about pressure and fear
- Collective decision-making on risky stories
- Support for journalists facing threats
- Public commitment to editorial independence
- Solidarity among newsrooms
5. Collaborative Journalism and Networks
Cross-Border Collaboration:
- International partnerships (shared investigations)
- Distributed reporting (multiple countries, harder to suppress)
- Shared resources (legal, technical, financial)
- Mutual protection (international attention on threats)
- Publication in multiple jurisdictions
Examples:
- International Consortium of Investigative Journalists (ICIJ)
- Organized Crime and Corruption Reporting Project (OCCRP)
- Forbidden Stories (continues work of threatened journalists)
- Global Investigative Journalism Network (GIJN)
Domestic Networks:
- State and regional journalism collaboratives
- Shared investigative resources
- Legal defense networks
- Training and security support
- Collective bargaining and advocacy
Benefits:
- Harder to suppress stories in multiple outlets
- Shared costs and risks
- Greater impact and reach
- Mutual support and solidarity
- International attention and protection
6. Alternative Platforms and Distribution
Digital Independence:
- Own your platform: Self-hosted websites, not just social media
- Email newsletters: Direct relationship with audience (Substack, Ghost)
- Podcasts and video: Multiple distribution channels
- Decentralized platforms: Mastodon, federated social media
- Mesh networks: Local wireless networks in crisis
- Print distribution: Physical newspapers and zines
Platform Resilience:
- Multiple hosting providers
- Distributed denial-of-service (DDoS) protection
- Content delivery networks (CDNs)
- Backup and mirror sites
- International servers
- Blockchain and decentralized storage
Circumvention Tools:
- VPN and proxy services
- Tor and anonymous browsing
- Encrypted messaging apps
- Satellite internet
- Radio and broadcast alternatives
7. Audience Building and Community Support
Direct Relationship with Readers:
- Membership and subscription models
- Regular communication and transparency
- Reader input and participation
- Community events and engagement
- Loyalty and trust building
Transparency and Accountability:
- Explain funding sources and business model
- Disclose conflicts of interest
- Corrections and accountability
- Behind-the-scenes access
- Financial transparency
Community Defense:
- Readers as advocates and defenders
- Crowdfunding for legal defense
- Public pressure on attackers
- Boycotts and economic consequences
- Social media amplification
For Citizens and Civil Society
8. Support Independent Journalism
Financial Support:
- Subscribe and donate to independent outlets
- Crowdfund investigative projects
- Boycott regime-captured media
- Support nonprofit journalism with tax-deductible donations
- Buy subscriptions as gifts
- Leave bequests to journalism organizations
Audience Support:
- Read, share, and amplify independent journalism
- Attend events and participate in community
- Provide tips and information to journalists
- Defend journalists facing attacks
- Testimonials and public support
Volunteer and Skills:
- Pro bono legal services
- Technical and security support
- Translation and language services
- Research and fact-checking
- Administrative and operational support
9. Media Literacy and Critical Consumption
Recognize Propaganda:
- Identify bias and framing
- Check sources and verify claims
- Recognize manipulation techniques
- Understand media ownership
- Compare multiple sources
Teach Media Literacy:
- School curricula and education
- Community workshops and training
- Library programs
- Online resources and guides
- Intergenerational teaching
Share Accurate Information:
- Fact-check before sharing
- Correct misinformation
- Amplify credible sources
- Model critical thinking
- Combat viral falsehoods
10. Organize and Advocate
Pressure Advertisers:
- Boycott companies advertising in regime media
- Support businesses advertising in independent media
- Public campaigns targeting advertisers
- Shareholder activism
- Consumer choice as political action
Legislative Advocacy:
- Anti-SLAPP laws
- Shield laws for journalists
- Media ownership limits
- Public broadcasting funding
- Freedom of information laws
- Whistleblower protections
Public Demonstrations:
- Protests supporting press freedom
- Vigils for imprisoned journalists
- Public pressure on regime
- International attention
- Solidarity actions
Legal Challenges:
- Challenge censorship laws
- Defend journalists in court
- Amicus briefs in press freedom cases
- Constitutional litigation
- International human rights complaints
For Media Owners and Executives
11. Ownership Structures That Resist Capture
Nonprofit Ownership:
- 501(c)(3) charitable organizations
- Foundation ownership
- Public benefit corporations
- No profit motive to exploit
- Mission-driven governance
Trust Ownership:
- Guardian/Scott Trust model (The Guardian)
- Ownership held in perpetuity for public benefit
- Cannot be sold to highest bidder
- Editorial independence protected
- Long-term sustainability focus
Cooperative Ownership:
- Worker-owned cooperatives
- Community-owned media
- Distributed ownership (many small owners)
- Democratic governance
- Aligned incentives
Family Ownership with Protections:
- Multi-class stock (voting vs. non-voting)
- Editorial independence clauses
- Board oversight of editorial decisions
- Long-term family commitment
- Values-driven ownership
Examples:
- The Guardian (Scott Trust)
- The Philadelphia Inquirer (Nonprofit ownership)
- The Tampa Bay Times (Poynter Institute)
- The Christian Science Monitor (Church ownership)
- Associated Press (Cooperative)
12. Financial Resilience Strategies
Diversification:
- Multiple revenue streams
- Geographic diversification
- Product diversification (print, digital, events)
- Avoid dependence on any single source
- Build reserves and endowments
Debt Management:
- Minimize or eliminate debt
- Avoid leveraged buyouts
- Conservative financial management
- Cash reserves for crisis periods
- Access to emergency funding
Revenue Innovation:
- Membership programs
- Premium subscriptions
- Events and experiences
- Training and consulting
- Licensing and syndication
- Grants and philanthropy
13. Legal and Regulatory Preparation
Preemptive Measures:
- Legal defense fund established
- Relationships with press freedom lawyers
- Insurance coverage adequate
- International legal support arranged
- Rapid response protocols
Regulatory Compliance:
- Understand all regulatory requirements
- Maintain impeccable compliance
- Document everything
- Anticipate harassment
- Challenge unjust regulations
Offensive Legal Strategy:
- Challenge unconstitutional laws
- Sue for harassment and retaliation
- Public interest litigation
- International human rights complaints
- Set precedents protecting press freedom
14. Staff Protection and Support
Security and Safety:
- Security training for all staff
- Threat assessment and response
- Legal support for threatened journalists
- Relocation assistance if needed
- Family protection measures
Mental Health and Wellbeing:
- Trauma counseling and support
- Burnout prevention
- Work-life balance
- Peer support networks
- Professional mental health services
Career Protection:
- Job security for threatened journalists
- Blacklist resistance and industry solidarity
- Legal defense for criminal charges
- Financial support during legal battles
- International job placement if needed
Union and Collective Bargaining:
- Newsroom unions
- Collective bargaining agreements
- Grievance procedures
- Just cause employment
- Solidarity and mutual support
For Technology Companies and Platforms
15. Platform Policies and Enforcement
Protect Journalists:
- Special protections for journalists and media
- Rapid response to threats and harassment
- Verification and authentication
- Priority support for press accounts
- Resist government pressure for censorship
Transparency:
- Publish transparency reports
- Disclose government requests
- Explain content moderation decisions
- Appeal processes for removals
- Independent oversight
Resist Censorship:
- Challenge government censorship orders
- Require legal process for content removal
- Notify users of government requests
- Fight overbroad demands
- International human rights standards
16. Technical Tools and Infrastructure
Provide Security Tools:
- End-to-end encryption
- Anonymous browsing (Tor support)
- Secure communications platforms
- Two-factor authentication
- Security key support
Circumvention Tools:
- VPN services
- Proxy support
- Mirror sites and caching
- Distributed hosting
- Censorship circumvention
Support Independent Media:
- Favorable algorithms for quality journalism
- Monetization support
- Technical assistance
- Infrastructure support
- Partnership programs
For Governments and Policymakers (Democratic)
17. Legal and Regulatory Protections
Constitutional Protections:
- Strong First Amendment or equivalent
- Judicial independence to enforce
- Constitutional courts
- International human rights commitments
Statutory Protections:
- Anti-SLAPP laws (Strategic Lawsuits Against Public Participation)
- Shield laws (reporter’s privilege, source protection)
- Whistleblower protections
- Freedom of Information laws
- Open meetings and records laws
- Prohibitions on prior restraint
Media Ownership Regulations:
- Limits on concentration and consolidation
- Cross-ownership restrictions
- Transparency in ownership
- Foreign ownership limits (carefully crafted)
- Public interest obligations
Public Broadcasting:
- Strong, independent public media
- Adequate funding insulated from politics
- Editorial independence guaranteed
- Professional governance
- Serve underserved communities
18. Economic Support for Journalism
Direct Support:
- Grants for investigative journalism
- Public interest journalism fund
- Local journalism support
- Tax credits for journalism employment
- Nonprofit journalism tax benefits
Indirect Support:
- Postal subsidies for news distribution
- Tax deductions for subscriptions
- Advertising tax credits
- Journalism training and education
- Infrastructure support
International Support:
- Fund journalism in authoritarian countries
- Support exiled journalists
- International journalism networks
- Press freedom advocacy
- Sanctions on regime officials attacking press
Part III: Resistance When Capture Is Advanced
19. Underground and Exile Journalism
When Operating in Hostile Environment:
Security First:
- Assume total surveillance
- Encrypted everything
- Anonymous sources and methods
- Compartmentalization
- Dead drops and secure meetings
- Burner phones and devices
Publication Strategies:
- Publish from abroad
- Multiple simultaneous outlets
- Anonymous publication
- Samizdat and underground distribution
- International platforms
- Blockchain and decentralized storage
Funding:
- International support
- Cryptocurrency donations
- Smuggled funds
- Diaspora support
- Foundation grants (international)
Historical Examples:
- Soviet samizdat (underground self-publishing)
- Nazi Germany exile press (published from abroad)
- Chinese underground media (Great Firewall circumvention)
- Iranian citizen journalism (Green Movement)
- Syrian war reporting (citizen journalists under fire)
20. Citizen Journalism and Alternative Media
When Professional Media Captured:
Citizen Reporting:
- Smartphone documentation
- Social media reporting
- Eyewitness accounts
- Crowdsourced verification
- Distributed journalism
Alternative Platforms:
- Blogs and independent websites
- Podcasts and video channels
- Social media accounts
- Messaging apps and groups
- Email newsletters
Verification and Quality:
- Fact-checking networks
- Verification tools and training
- Editorial standards
- Corrections and accountability
- Collaborative verification
Protection:
- Anonymity and pseudonyms
- VPNs and encryption
- Secure communications
- Legal support networks
- International attention
21. International Journalism and Exile Media
Reporting from Abroad:
Advantages:
- Physical safety
- Legal protection
- Access to resources
- International platforms
- Coordination with local sources
Challenges:
- Distance from story
- Source access difficult
- Credibility questions
- Funding challenges
- Regime propaganda attacks
Strategies:
- Maintain local sources and networks
- Partner with underground journalists
- Use technology for remote reporting
- Collaborate internationally
- Focus on investigations and analysis
Examples:
- Radio Free Europe/Radio Liberty (Cold War)
- Bellingcat (open-source investigations)
- Meduza (Russian independent media in exile)
- Özgür Gündem (Turkish journalism in exile)
- Venezuela exile media (reporting from abroad)
Part IV: Strategic Principles
22. Core Principles for Resisting Media Capture
1. Independence Above All
- Economic independence enables editorial independence
- Diversify funding, minimize vulnerability
- Ownership structures that resist capture
- No dependence on regime or allies
2. Solidarity and Collaboration
- Journalists and outlets support each other
- Industry-wide resistance to capture
- International partnerships
- Collective defense stronger than individual
3. Transparency and Accountability
- Explain funding and business model
- Admit mistakes and correct
- Maintain public trust
- Accountability to audience, not power
4. Professional Excellence
- High-quality journalism is best defense
- Accuracy and fairness
- Investigative depth
- Public service mission
5. Audience Connection
- Direct relationship with readers
- Community support and defense
- Membership and participation
- Mutual loyalty and trust
6. Legal and Physical Security
- Prepare for attacks
- Legal defense ready
- Physical and digital security
- Protect staff and sources
7. Resilience and Adaptation
- Prepare for worst-case scenarios
- Multiple backup plans
- Flexibility and innovation
- Long-term sustainability
8. International Dimension
- Global partnerships and support
- International attention and pressure
- Cross-border collaboration
- Exile and refuge options
23. Stages of Defense
Prevention (Before Capture Begins):
- Build economic independence
- Establish legal protections
- Create resilient ownership structures
- Develop audience relationships
- International partnerships
Early Defense (Capture Beginning):
- Public exposure of pressure
- Legal challenges
- Industry solidarity
- Audience mobilization
- International attention
Active Resistance (Capture Advancing):
- Underground journalism
- Exile media
- Citizen journalism
- International publication
- Continued investigations
Survival (Capture Complete):
- Exile operations
- Underground networks
- International platforms
- Preserve capacity for restoration
- Document abuses for accountability
Part V: Case Studies and Lessons
24. Success Stories: Media That Resisted Capture
The Guardian (UK)
Model: Scott Trust ownership Success Factors:
- Trust ownership prevents sale
- Reader support model
- Editorial independence protected
- International reach
- Investigative excellence
Lessons:
- Ownership structure matters
- Reader support enables independence
- Quality journalism builds loyalty
- International presence provides security
ProPublica (USA)
Model: Nonprofit investigative journalism Success Factors:
- Foundation funding
- No advertising dependence
- Investigative focus
- Collaboration with other outlets
- Public service mission
Lessons:
- Nonprofit model viable
- Investigative journalism attracts support
- Collaboration amplifies impact
- Mission-driven sustainability
Mediapart (France)
Model: Subscriber-supported independent Success Factors:
- No advertising
- Subscriber ownership
- Investigative excellence
- Legal victories against powerful targets
- Editorial independence
Lessons:
- Subscriber model works
- Independence enables aggressive reporting
- Legal defense essential
- Quality attracts paying audience
Rappler (Philippines)
Model: Independent digital news Success Factors:
- Diverse funding (grants, crowdfunding, ads)
- Strong social media presence
- Fact-checking and verification
- International support
- Legal defense and resilience
Challenges:
- Government harassment and lawsuits
- License threats
- Founder Maria Ressa arrested
- Continued operations despite pressure
Lessons:
- International attention provides protection
- Legal defense critical
- Resilience and persistence
- Solidarity matters
25. Cautionary Tales: Media Capture Successes
Hungary
How Capture Succeeded:
- Oligarch allies bought major outlets
- Government advertising weaponized
- Critical outlets bankrupted
- Public broadcaster purged
- Regulatory pressure on remaining independents
Lessons:
- Economic pressure highly effective
- Ownership consolidation dangerous
- Government advertising as weapon
- Need early resistance
- International attention insufficient alone
Turkey
How Capture Succeeded:
- Journalists imprisoned en masse
- Outlets seized and sold to allies
- Self-censorship from fear
- Social media censorship
- Exile of critical journalists
Lessons:
- Legal harassment extremely effective
- Physical threats silence journalists
- Need international refuge
- Exile media important
- Early resistance critical
Venezuela
How Capture Succeeded:
- Broadcast licenses not renewed
- Newsprint and currency denied
- Journalists charged with terrorism
- Self-censorship to survive
- Independent media marginalized
Lessons:
- Regulatory power as weapon
- Economic pressure (newsprint, currency)
- Criminal charges intimidate
- Gradual capture harder to resist
- Need alternative distribution
Part VI: Practical Action Plans
26. For Individual Journalists
Immediate Actions:
- [ ] Assess personal risk and threat level
- [ ] Improve digital security (encryption, VPN, secure devices)
- [ ] Document threats and harassment
- [ ] Connect with press freedom organizations
- [ ] Establish secure communication with sources
- [ ] Review employment contract and protections
- [ ] Consider legal representation
- [ ] Build financial reserves
- [ ] Develop international network
- [ ] Plan for worst-case scenarios (exile, imprisonment)
Ongoing Practices:
- [ ] Maintain highest professional standards
- [ ] Diversify sources and methods
- [ ] Collaborate with other journalists
- [ ] Protect sources rigorously
- [ ] Build public support and audience
- [ ] Stay connected to international journalism community
- [ ] Continue professional development
- [ ] Support colleagues facing threats
- [ ] Document and expose pressure
- [ ] Maintain physical and mental health
27. For News Organizations
Immediate Actions:
- [ ] Assess ownership structure vulnerability
- [ ] Diversify revenue streams
- [ ] Establish legal defense fund
- [ ] Improve security (physical and digital)
- [ ] Review and strengthen editorial independence
- [ ] Build audience relationships
- [ ] Develop international partnerships
- [ ] Create crisis response plans
- [ ] Train staff on security
- [ ] Establish whistleblower protections
Strategic Planning:
- [ ] Consider ownership structure changes
- [ ] Develop sustainable business model
- [ ] Build cash reserves
- [ ] Strengthen editorial firewall
- [ ] Create succession plans
- [ ] Develop exile/backup plans
- [ ] Build international distribution
- [ ] Establish legal defense network
- [ ] Create staff protection programs
- [ ] Plan for various threat scenarios
28. For Citizens and Civil Society
Individual Actions:
- [ ] Subscribe to independent media
- [ ] Share and amplify quality journalism
- [ ] Develop media literacy skills
- [ ] Support journalists facing threats
- [ ] Boycott captured media
- [ ] Pressure advertisers
- [ ] Attend press freedom events
- [ ] Donate to journalism nonprofits
- [ ] Provide tips and information to journalists
- [ ] Defend press freedom publicly
Collective Actions:
- [ ] Organize press freedom advocacy
- [ ] Create legal defense funds
- [ ] Pressure legislators for protections
- [ ] Boycott and consumer campaigns
- [ ] Public demonstrations for press freedom
- [ ] Support journalist unions
- [ ] Create community media
- [ ] Teach media literacy
- [ ] Build international solidarity
- [ ] Document and expose media capture
Conclusion
The Stakes
Free press is essential to democracy:
- Exposes corruption and abuse
- Informs citizens for self-governance
- Holds power accountable
- Provides early warning of authoritarianism
- Enables organizing and resistance
Once media is captured:
- Citizens lose access to accurate information
- Propaganda replaces news
- Organizing resistance becomes extremely difficult
- Authoritarian consolidation accelerates
- Democratic restoration much harder
The Challenge
Media capture is insidious:
- Gradual and incremental
- Uses economic and legal pressure
- Creates self-censorship
- Divides and conquers
- Difficult to reverse once complete
The Opportunity
Resistance is possible:
- Economic independence protects editorial independence
- Alternative ownership structures resist capture
- Digital platforms enable circumvention
- International collaboration provides security
- Audience support sustains independent journalism
- Legal defense can prevail
- Solidarity strengthens resistance
The Path Forward
Prevention is easier than restoration:
- Act early when capture begins
- Build resilient structures now
- Support independent journalism
- Demand legal protections
- Create alternative platforms
- Build international networks
- Maintain professional excellence
- Connect with audiences
Resistance requires:
- Journalists: Courage, professionalism, solidarity
- Media owners: Independence, resilience, mission commitment
- Citizens: Support, literacy, advocacy
- Tech companies: Tools, platforms, resistance to censorship
- Governments (democratic): Legal protections, economic support
- International community: Pressure, support, refuge
Bottom Line
Media capture can be prevented and resisted, but requires:
- Early recognition of warning signs
- Economic independence from regime pressure
- Legal defense against harassment
- Security (physical and digital)
- Solidarity among journalists and outlets
- Audience support and community defense
- International collaboration and attention
- Professional excellence and integrity
- Resilience and adaptation
- Long-term commitment to press freedom
The choice is clear: Defend press freedom now, or lose the ability to defend anything else later.
Related Documents
- federal-authoritarianism-resistance.md – Overall resistance strategies
- insurrection-act.md – Military deployment powers
- insurrection-act-response.md – Responding to military deployment
- CONTEXT-narcissistic-president-advisor.md – Authoritarian patterns
- best-practices.md – Evidence-based resistance strategies
Additional Resources
Press Freedom Organizations
- Committee to Protect Journalists (CPJ)
- Reporters Without Borders (RSF)
- Freedom of the Press Foundation
- Reporters Committee for Freedom of the Press
- PEN America
- International Federation of Journalists (IFJ)
- Article 19
- Index on Censorship
Security and Technical Support
- Electronic Frontier Foundation (EFF)
- Access Now
- Tactical Tech
- Security First
- Digital Defenders Partnership
Legal Support
- Media Defence (international)
- Doughty Street Chambers (UK)
- Knight First Amendment Institute (USA)
- European Centre for Press and Media Freedom
Journalism Networks
- Global Investigative Journalism Network (GIJN)
- International Consortium of Investigative Journalists (ICIJ)
- Organized Crime and Corruption Reporting Project (OCCRP)
- Forbidden Stories
Training and Education
- Dart Center for Journalism and Trauma
- Poynter Institute
- International Center for Journalists (ICFJ)
- Thomson Reuters Foundation
Last Updated: February 2, 2026
Status: Active guidance – media capture in progress
Classification: Public – Share Widely
“Freedom of the press is not just important to democracy, it is democracy.”
— Walter Cronkite
“Journalism is printing what someone else does not want printed; everything else is public relations.”
— George Orwell (attributed)
“The press was to serve the governed, not the governors.”
— Justice Hugo Black, New York Times Co. v. United States (1971)
