Based on what I know about court reporting, this appears to be a business rather than a royalty.
The IRS' Publication 17 says that "Earned income is ...amounts received as pay for
work you actually perform."
If I am correct, even in the simple case, a court reporter does some of the basic functions of a business - buying supplies (paper or DVDs or memory sticks), billing clients, advertising (even if word of mouth) services, etc.
Note that Court reporting has an SOI industry code - 561492 Court Reporting and Stenotype Services, and I see a number of articles that speak to the tax implications of whether or not you should incorporate as your court reporting activity grows. This would make sense
only if it were a business.
