Eastland v. United States Servicemen's Fund

In Eastland v. United States Servicemen's Fund, 421 U.S. 491, the United States Supreme Court held as follows: The applicability of the Clause to private civil actions is supported by the absoluteness of the terms 'shall not be questioned' and the sweep of the term 'in any other Place.' In reading the Clause broadly we have said that legislators action within the sphere of legitimate legislative activity 'should be protected not only from the consequences of litigation's results but also from the burden of defending themselves. . . . a private civil action . . . creates a distraction and forces Members to divert their time, energy, and attention from their legislative tasks to defend the litigation. Private civil actions also may be used to delay and disrupt the legislative function. The court further held that in determining whether particular activities other than literal speech or debate fall within the 'legitimate legislative sphere' the court must consider whether such activities took place in a session of the legislature by one of its members in relation to the business before it. More specifically, it is necessary to determine if the activities are an integral part of the deliberative and communicative processes by which legislators participate in committee and legislative proceedings with respect to the consideration and passage or rejection of proposed legislation or with respect to other matters which are within the jurisdiction of the legislature.