In O'Neill v. Oakgrove Constr. (71 N.Y.2d 521 [1988]), the Court held that article I, 8 provides a qualified reporter's privilege against disclosure of nonconfidential photographs, though no such privilege had been recognized by the United States Supreme Court. In support of its decision, the Court in O'Neill observed that "the expansive language of our State constitutional guarantee, its formulation and adoption prior to the Supreme Court's application of the First Amendment to the States, the recognition in very early New York history of a constitutionally guaranteed liberty of the press, and the consistent tradition in this State of providing the broadest possible protection to the sensitive role of gathering and disseminating news of public events all call for particular vigilance by the courts of this State in safeguarding the free press against undue interference." (Id. at 528-529.)