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The Justice Department’s decision to seek a court order for the CNN reporter’s records would have required the approval of the attorney general at the time, William P. Barr, as it would have in the Post case.

Mr. Trump frequently took aim at CNN and The Post, accusing the outlets of peddling “fake news.” In early 2017, he said he had directed the Justice Department to look into the leaks, which he called “criminal.”

Several months after Mr. Trump’s comments, Jeff Sessions, the attorney general at the time, announced that the Justice Department was pursuing about three times as many leak investigations as were open at the end of the Obama administration.

Mr. Sessions said that the F.B.I. had created a counterintelligence unit to specialize in such cases. Former federal law enforcement officials said the leak cases were consolidated, with prosecutors and agents working them. Leak prosecutions are rare and notoriously difficult.

The Obama administration oversaw nearly a dozen leak-related prosecutions, more than all previous presidents combined.

The Justice Department’s rules require investigators to exhaust all other ways to obtain the information they are seeking before examining reporters’ phone logs or subpoenaing journalists for notes or testimony that could force them to help investigators identify their confidential sources, or face imprisonment for contempt. The rules are intended to limit any chilling effect on the news-gathering process.

After the department under President Barack Obama subpoenaed the phone records of editors and reporters at The Associated Press and Fox News in separate leak investigations, the administration endured a backlash from the news media.