U.S. Press Freedom Tracker

New York County Supreme Court judge quashes subpoena for HBO documentary outtakes

Incident Details

Date of Incident
March 27, 2019
New York, New York

Subpoena/Legal Order

Legal Orders
Legal Order Target
Legal Order Venue
Mario Anzuoni/File/Reuters

The New York County Supreme Court ruled that the state’s shield law applies to Dwayne “The Rock” Johnson in his role producing the 2017 documentary film, “Rock and a Hard Place.”

— Mario Anzuoni/File/Reuters
March 27, 2019

New York County Supreme Court Judge Carol Edmead quashed a subpoena for outtakes from the HBO documentary “Rock and a Hard Place” on June 5, 2019, citing New York’s shield law.

Christy Laster, a former correctional officer who appeared in the documentary, stands charged of bribery, grand theft and extortion, but alleged the footage she sought through the subpoena would exonerate her, according to the ruling. Laster argued that because Dwayne “The Rock” Johnson appeared in and produced the documentary, it was rendered a “celebrity reality TV show” and therefore would not be protected under the statute.

Edmead dismissed this categorization, writing in her decision that Laster “cites no authority for the notion that the mere involvement of a celebrity in a project renders it somehow incapable of being classified as a documentary, or that a celebrity known for other endeavors cannot be deemed a ‘journalist’ under the [shield law].”

In addition to his credit as an executive producer for “Rock and a Hard Place,” Johnson was the executive producer of the episode “Stand Your Ground” in the “Finding Justice” series and of the feature documentary “Racing Dreams.”

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