The techniques of constitutional interpretation established by the Supreme Court to balance the right of the press to report on the criminal justice system against other rights have led to varied results in the lower federal courts. On the one hand, the scrutiny structure has led to the eradication of most direct prior restraints on the press. Moreover, post-publication sanctions for press reporting on criminal justice have been virtually eliminated. On the other hand, prior restraints on participants in criminal trials, when challenged by the media, are upheld with little scrutiny in some federal courts. Also, press access to criminal proceedings, even if given some relatively high level of constitutional scrutiny, has been frustrated in a number of situations that arguably should have resulted in open proceedings.