Von Bulow v. Von Bulow

Von Bulow v. Von Bulow, 811 F.2d 136 (2nd Cir. 1987), was a case appealed from a contempt ruling after a United States District Court rejected the claim of a reporter's privilege by Claus von Bulow and Andrea Reynolds.

Reynolds, a paralegal, appealed a contempt ruling after she refused to submit an unpublished document for discovery. The United States Court of Appeals for the Second Circuit upheld the contempt order. The Court reasoned that a person who had gathered information for private use without the intent to gather the information as part of an investigation for a publication was not entitled to a reporter's privilege.