In March 2012, Iowa and Utah passed “Ag-Gag” laws in response to a series of high-profile undercover investigations of farms by animal activists. The laws were framed as generally applicable fraud prohibitions. But their aim was clear: to stop animal activists exposing the treatment of animals on industrial-scale farms. A constitutional challenge to the laws now seems likely. A court hearing such a challenge should subject the Ag-Gag laws to heightened First Amendment scrutiny under the news gathering framework of Cohen v. Cowles Media Co. The laws cannot survive such scrutiny.