A study analyzed U.S. Supreme Court Justice Lewis Powell's court opinions on First Amendment issues that affect the daily work of journalists. The results showed that he preferred compromises, guidelines, and tests to either/or solutions. Because Powell sought to balance all interests, he developed no firm theoretical position on the First Amendment, nor did he advance freedom of the press. Though his opinions stated that freedom of the press was a societal interest to be protected, he gave the press no greater First Amendment protection than that given the average citizen. Powell's importance to the Burger and Rehnquist courts was due to their fragmentation and his role as middle man, not to his overriding judicial philosophy. (Four pages of endnotes are attached.) (MHC)