On December 29, 2009, agents of the Transportation Security Administration (TSA) interrogated and served subpoenas on two travel bloggers who had posted a TSA security directive put in place after the failed Christmas day "underwear bomber" attempt. The two bloggers, Steven Frischling and Chris Elliott, posted the text of the directive on December 27 after confusion arose over air travel procedures and restrictions in the wake of the failed terrorist attack.

Frischling, a freelance travel writer and photographer who publishes a blog for KLM Airlines and Flying With Fish, complied with the subpoena, in part because he did not know the identity of the source, there is no federal shield law to protect him, and he felt that he could lessen the ordeal by cooperating. According to Wired, agents went through his phone contacts and determined it was necessary to take an image of his hard drive. In the process of trying to copy files, agents damaged Frischling’s laptop. With Frischling’s permission, they seized the computer, departed, and later returned it.

Elliott, who publishes the blog Elliott and writes a column for the Washington Post and MSNBC, refused to divulge his source and retained counsel. The TSA then backed off and ultimately withdrew the subpoena on December 31.

That same day, the TSA notified Frischling that it was withdrawing the subpoena.  It is not clear whether the agency will compensate Frischling for damaging his laptop. 

During a lawsuit brought against North Dakota and the North Dakota's Workforce and Safety Insurance (WSI) by Dr. James Long , the State subpoenaed Chad Nodland, a blogger who maintains NorthDecoder.com. In the lawsuit, Long claimed that he had been unfairly dismissed after shedding light on what he believed to be illegal conduct by WSI.

According to Nodland's post about the subpoena he received, the subpoena asked Nodland to turn over any emails he exchanged with Long, cell phone records and notes that show or detail any coversations he may have had with Long, and blogs authored by Long. Nodland then sent a letter to the State's attorneys, objecting to the subpoena for various reasons, including the protection he had under North Dakota's shield law.

Nodland has yet to hear from the State's attorneys after sending his reply.

During a sex discrimination lawsuit brought against Coweta County, Georgia by former county official Leigh Schlumper, the county subpoenaed Sarah Faye-Campbell, a reporter for The Newnan Times-Herald. 

According to an article in the Times-Herald, the subpoena asked Faye-Campell "to name the anonymous source that provided her with copies of letters written by disgruntled firefighters" that were at issue in the discrimination lawsuit. The Times-Herald objected to the subpoena on the ground that Georgia's shield law protected the source's identity, and Coweta County agreed to suspend the subpoena pending further developments in the case.

Ultimately, the parties to the discrimination lawsuit stipulated to dismissal of the case, making the subpoena issue moot. 

Aleksandra Vinogradov, a professor at Montana State University, subpoenaed the Bozeman Daily Chronicle for information concerning comments made on the Chronicle's website in connection with two articles published in March and April 2009 regarding the trial in Vinogradov's gender discrimination suit against her employer, Montana State University.

Vinogradov sought this information to support a request for a new trial in her discrimination lawsuit against MSU, which ended in a jury verdict against her in April 2009. Her attorneys argued that one of the commenters to the April 2009 article who posted under the pseudonym “mbcomstock” was Brandon Comstock, one of the jurors in the case. The comment in question read: "Note that this was the third time this same woman has sued the university for discrimination, and her third loss. Maybe, just maybe, instead of everybody else being conspiring liars hiding a ‘big dirty secret,’ the problem is really her." In a May 2009 hearing, Comstock testified that he was not the author of the comment, but acknowledged that his father might have written it.

Vinogradov claimed this post proved the jury was improperly informed of her prior suits against MSU. She moved for a new trial based on jury misconduct and served a subpoena on the newspaper requesting that the Chronicle turn over:

"1) copies of all postings made to the Chronicle's website or blog relating to the two articles; 2) the names and identities off [sic] persons and organizations that posted such comments; 3) the IP addresses associated with each comment posted; 4) the IP addresses associated with each viewer of the two articles during the period of March 23, 2009 to April 3, 2009; 5) all computer logs generated in connection with the two articles; and 6) any and all e-mail communications and other written communications that the Chronicle and its website, its agents and its employees have received or sent on or after March 23, 2009 relating to the two articles." 

Ruling at 2. In addition, Vinogradov filed an emergency motion to perpetuate testimony pending appeal, so that information on the posting could be considered with her request for a new trial. 

On June 3, 2009, the Chronicle opposed Vinogradov's motions, arguing that the information and documents she sought "are protected under Montana's Media Confidentiality Act, specifically  26-1-902, MCA." Ruling at 3. The next day, MSU also opposed Vinogradov's motion to perpetuate, arguing that "the information she seeks is not relevant to the jury misconduct issue" and therefore did not satisfy procedural requirements. Id. 

On June 5, 2009, the court denied Vinogradov's motion to perpetuate testimony pending appeal on procedural grounds. The court did not address the newspaper's shield law argument or rule on its motion to quash the subpoena.  Later in June, the court denied Vinogradov's motion for a new trial. 

Vinogradov reportedly will appeal this result.