Sunday, December 8, 2013

United States v. Helstoski case brief

United States v. Helstoski case brief summary
442 U.S. 477 (1979)


CASE SYNOPSIS
The government sought certiorari review of an order of the United States Court of Appeals for the Third Circuit affirming the district court's order ruling on the admissibility of evidence, under the Speech or Debate Clause of U.S. Constitutional art. I, § 6, at a trial on charges that defendant, a former member of the U.S. House of Representatives, had accepted money in return for promising to introduce legislation.

CASE FACTS
Defendant, a former member of the U.S. House of Representatives, was charged with various offenses relating to the acceptance of money from private individuals in order to introduce legislation. Defendant brought a motion to dismiss the indictment, claiming that the grand jury process had been abused, and that the indictment violated the Speech or Debate Clause of U.S. Constitutional art. I, § 6. The district court denied the motion, but ruled that the government could not offer evidence of defendant's actual performance of any legislative act at trial. The circuit court affirmed the district court's decision, and the court affirmed the circuit court's order.

DISCUSSION
  • Article I, § 6, prohibited the introduction of any act done in relation to the business of the U.S. Congress, but inquiry into promises to deliver a vote at some time in the future was not subject to the immunity. 
  • Further, defendant did not waive the immunity privilege because the waiver must be clear and unambiguous. 
  • Moreover, the privilege was not waived by the passage of 18 U.S.C.S. § 201. 
  • The purpose of § 201 was to provide a check on the legislative branch, not to waive the individual members' rights.
CONCLUSION
The court affirmed the circuit court's order affirming the district court's ruling regarding the admissibility of evidence relating to legislative acts because defendant, a former member of the U.S. House of Representatives, was entitled to immunity for activities generally done in the performance of his duties as a U.S. Congressman, and defendant did not waive his entitlement to immunity.


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