State v. Carl Gibson

**317 The State appeals the order of the Superior Court ( McNamara , J.) granting news reporter Nicholas Reid's (Reid) motion to quash the State's subpoena compelling him to testify against the defendant, Carl Gibson. We reverse and remand.

I

The relevant facts follow. Republican candidate Yvonne Dean-Bailey (Dean-Bailey) was running in a May 19, 2015 special election for State Representative from Rockingham County District 32. On May 14, 2015, the defendant, a volunteer for the opposing Democratic Party candidate, allegedly issued a false press release stating that Dean-Bailey was dropping out…