Hutchinson v. Proxmire (1978)
- Docket
- 78-680
- Decided
- 1978-01-01
Summary
Question: Were Proxmire's activities and statements against Hutchinson's research protected by the Speech and Debate Clause of Article I, Section 6 of the Constitution? Conclusion: No. The Court affirmed the decision of the lower court and held that Proxmire's statements in his newsletters and press releases were not protected by the Speech and Debate Clause. However, in upholding this ruling, the Court also found that Proxmire's statements were not made with "actual malice" and thus, were not libelous. Chief Justice Burger, relying on the Court's finding in Doe v. McMillan (1973), concluded that while speeches in Congress and discussions with staff were protected by Section 6, statements in newsletters and press releases were not because they were not "essential to the deliberations of the Senate" nor were they part of the legislature's "deliberative process."