Warrants and subpoenas issued to journalists have been a top concern among the U.S. news media for several years, a period in which the administration of President Barack Obama has greatly increased the prosecutions of leakers who have disclosed government secrets to the press. As part of these investigations, the Department of Justice has several times swept reporters into its scrutiny by issuing subpoenas to determine the identity of confidential sources. That has occurred through the subpoena of the phone records of Associated Press reporters from the telephone company, the labeling of Fox News reporter James Rosen as a “co-conspirator” under the Espionage Act in order to obtain his emails, and, most recently, the pursuit of James Risen’s testimony in the trial of Donald Sterling.