In the United States journalists enjoy a constitutionally protected right to publish their work. The right, of course, is enshrined in the First Amendment of the Bill of Rights, whose guardian angel has been the US Supreme Court. Reviewing the press Near v. Minnesota's work this century, author James E. Leahy wrote "the justices should be given high marks for their interpretations of the freedom of the press provision of the First Amendment." For the prison press, the opposite has been the case. The Supreme Court has refused to extend the constitutional protection of the First Amendment to prison journalists. The judiciary's reluctance to interfere with the running of prisons stemmed first from a belief that the law made convicted persons outlaws, stripping them of their legal rights and privileges as part of their punishment. Prisoners grew more assertive and militant on matters of civil rights.