A district court in Nevada ruled that neither online news portals, nor journalists are protected by the state’s journalist shield laws, unless they are members of the Nevada Press Association. The case concerned a defamation action brought by Gilman, a local public figure, against Toll, the owner and editor of a local news portal in relation to a series of articles about Gilman's business activities. Gilman, as a public figure had to prove actual malice, and therefore sought evidence obtained from Toll’s sources. The Court ruled that under under Nevada statutes online news sources were not “newspapers” since they did not appear in print, and thus would need to be members of the state's press association to receive protection.  However, the Court ruled that Toll’s sources were protected under the shield law from the time Toll joined the Nevada Press Association in August 2017, but sources of information procured before that date were unprotected. Hence, Gilman’s request to extend the discovery deadline to further investigate Toll’s sources before August 2017 was granted.