In July 2004, "Branzburg" was cited as precedent by United States District Court Chief Judge Thomas Hogan in a memorandum opinion denying a motion to quash two grand jury subpoenas issued to reporters. NBC Washington Bureau Chief Tim Russert and "Time" magazine reporter Matthew Cooper challenged the subpoenas issued in connection with the leak of the identity of former CIA operative Valerie Plame, citing their First Amendment rights as reason not to reveal their confidential sources. In the opinion, Hogan wrote: