The United States Supreme Court has held that there is no first amendment privilege against discovery into the editorial process of a media defendant in a defamation action by a public figure.
Herbert v. Lando, 441 U.S. 153 (1979)
Jerry V. Haines,
Constitutional Law - First Amendment - Defamation - Public Figures - Discovery - Editorial Process - Privilege,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol18/iss3/13