ABSTRACT
The Yale speech broke important new ground. The Supreme Court had never really addressed the question posed by Justice Stewart-whether the press clause has an independent purpose and meaning-much less given his bold answer. The press clause, he said, did not merely join with the speech clause to guarantee freedom of expression to all; that would make it “a constitutional redundancy.”7 Rather, the “primary purpose” of those who framed it was “to create a fourth institution outside the Government as an additional check on the three official branches/’8 That purpose, Justice Stewart said, informed recent Supreme Court decisions on the rights of the press.9
