When James and Janet Baker filed suit against Goldman Sachs & Co., alleging that inadequate research by the investment bank cost them $300 million, they likely never intended to test the scope of New York’s journalist shield law.

But their efforts to force Wall Street Journal reporter Jesse Eisinger to substantiate their claim against Goldman ended up before the 2nd Circuit, which, on Feb. 15, upheld a ruling from the Federal District Court for the Southern District of New York, quashing their subpoena of Eisinger.