The clash between the First and Sixth Amendments continues to be a major concern for both journalists and the courts. This paper reviews the major cases in the evolution of the "fair trial/free press" controversy from the "Irvin vs. Dowd" decision in 1961 to the Blackmun decision in 1975. The attempt is made to answer the question of when, and if, direct restraint of the press is necessary in a criminal proceeding; alternatives to this course, which can ensure protection of both First and Sixth Amendment rights, are examined. The analysis concludes with the recommendation of an unrestrained press in coverage of criminal trials, with the right to pursue information regardless of restrictions placed on sources. Control of sources within the criminal judicial system is advocated. Protecting individual rights under both constitutional provisions is, however, perceived as the responsibility of both the press and the judicial system. (Author/KS)