Provided Chen qualifies as a "journalist" under state law, as both criticisms regarding the issuing of the warrant were specific to journalists. (The criticisms regarding the way it was carried out are a separate issue.)

A link posted on HN the other day noted that, in the state of New Jersey, bloggers aren't considered journalists. Depending on context, editors may or may not be considered journalists. I don't know the relevant California state laws or court decisions.