In Commonwealth v. Held, a media company appealed from a trial court’s denial of its request for the names of jurors after they deadlocked and a mistrial was granted, but before the retrial. The Superior Court acknowledged that the 1st Amendment was implicated, but, since the trial judge simply said he would not divulge the names until after the case was resolved, strict scrutiny was not applicable. Instead, the trial court’s order was found to be a reasonable restriction.