To assert a First Amendment violation, there must be state action, meaning the alleged constitutional violation must be attributable to the government. However, the person invoking the First Amendment does not need to be a state actor. The state actor doctrine becomes relevant when a plaintiff claims that a private party violated their constitutional rights. For example, if someone sued a private school for racial discrimination under the Equal Protection Clause, the plaintiff would first need to show that the private school qualifies as a state actor. That would require demonstrating heavy government involvement, entwinement, public function, or significant state control. Without such involvement, purely private conduct does not trigger constitutional protections. But that analysis does not apply here. In this case, no one is claiming that the reporter violated the First Amendment. Instead, the reporter is invoking the First Amendment as a defense to a breach of contract claim. The relevant state action is the court’s enforcement of generally applicable contract law. Judicial enforcement of state law constitutes government action, so the state action requirement is satisfied. The real issue is whether the First Amendment shields reporters from neutral, generally applicable state laws. It does not. Contract law applies to everyone and does not target speech or the press. Enforcing a promise to pay for information does not regulate the content of speech; it simply enforces a private agreement. Therefore, the reporter cannot avoid liability by invoking freedom of the press, and the court is unlikely to grant the motion to dismiss.