In United States v. Brewster, 408 U.S. 501, 92 S. Ct. 2531, 33 L. Ed. 2d 507 (1972), the U.S. Supreme Court held that the Speech and Debate Clause did not immunize a former U.S. Senator from a criminal indictment for bribery. In reaching this conclusion, the Supreme Court observed that members of Congress engage in numerous activities, such as assisting constituents in procuring government contracts and giving speeches, that are "political" rather than legislative activities. The Supreme Court noted that "it has never been seriously contended that these political matters, however appropriate, have the protection afforded by the Speech and Debate Clause." Id. at 512.