U.S. Press Freedom Tracker

Journalist subpoenaed in the prosecution of a serial killer

Incident Details

April 30, 2021 - Update

Subpoena of journalist in the prosecution of a serial killer dropped following defendants death

The subpoena for journalist and author Jillian Lauren Shriner’s unpublished source communications was dismissed as moot on April 30, 2021, following the death of the defendant in the underlying criminal case.

Shriner was subpoenaed by Samuel Little, who the FBI says is the most prolific serial killer in U.S. history, on Nov. 25, 2020. In Shriner’s interviews with Little, who at the time was serving three consecutive life sentences for murdering three women in Los Angeles, he confessed to dozens of additional homicides.

After a trial court in California ordered Shriner to comply with the subpoena, she filed an emergency appeal with the California Court of Appeal. Little died on Dec. 30, rendering the case against him effectively moot. Presiding Judge Manuel Ramirez signed a decision dismissing the petition against Shriner four months later.

November 25, 2020

On Nov. 25, 2020, journalist and author Jillian Lauren Shriner was subpoenaed by Samuel Little for “unpublished communications with her sources.” The subpoena was issued in connection to Little’s prosecution in the killing of a woman in San Bernardino, California.

In 2018, Little, who the FBI says is the most prolific serial killer in U.S. history, confessed to some 90 murders committed between 1970 and 2005. Fifty of the confessions made by Little have been verified by law enforcement, according to the FBI.

Shriner started talking to Little after she’d interviewed an Los Angeles Police Department detective who had prosecuted him and suspected him of having committed several additional unsolved murders across the country. In her interviews with Little, who at the time was serving three consecutive life sentences for murdering three women in Los Angeles, he confessed to dozens of additional homicides.

A trial court compelled Shriner to comply with the subpoena. On Dec. 23, Shriner appealed the decision with the California Court of Appeal, stating that “to disclose unpublished communications with her sources flagrantly violates California’s shield laws” and that the decision “disregards the fundamental principle, enshrined in California’s Constitution, that journalists must be independent of the judicial process and able to protect their unpublished information, including communications with sources. The Court of Appeal stayed the trial court’s order.

On Dec. 30, Little, 80, died, rendering the criminal case against him and the subpoena effectively moot. The Court of Appeal, though, has not yet dismissed the case and, on Feb. 2, 2021, granted the public defender’s request for an extension to file its response to Shriner’s petition by March 11.

Neither Shriner nor the public defender’s office responded to a request for comment as of press time.

The U.S. Press Freedom Tracker catalogues press freedom violations in the United States. Email tips to [email protected]