By Dave Itzkof, New York Times, January 14/15, 2011

A federal appeals court has ruled that Joe Berlinger, a filmmaker who was ordered to hand over footage from his 2009 documentary “Crude” to the Chevron Corporation, cannot invoke a journalist’s privilege in refusing to do so because his work does not constitute an act of independent reporting....

“Given all the circumstances of the making of the film,” the judges wrote, “as reasonably found by the district court, particularly the fact that Berlinger’s making of the film was solicited by the plaintiffs in the Lago Agrio litigation for the purpose of telling their story, and that changes to the film were made at their instance, Berlinger failed to carry his burden of showing that he collected information for the purpose of independent reporting and commentary.”....

It's an important ruling because it is basically saying that if you are taking an advocacy position for one perspective on a story, you don't get the protections.