An anti-abortion group of self-proclaimed citizen journalists, Center for Medical Progress, secretly videotaped Planned Parenthood after creating false identities and a fake company to infiltrate restricted areas. The group released the project "Human Capital" in 2015, which includes various documentary-like videos accusing Planned Parenthood clinics in California of selling aborted fetal tissue. The activists argued that its project was protected by the First Amendment, but the U.S. Court of Appeals for the Ninth Circuit affirmed that no journalist is above the law.