Gravel v. United States

The Gravel decision has been used to determine the scope of executive and judicial immunity under the Speech or Debate Clause. The important findings in Gravel were that a congressional aid enjoys the same immunity as a Member of Congress and that the immunity under the Speech or Debate Clause is limited to legislative activity. In Stump v. Sparkman (1978) the Court held that judges are also absolutely immune from liability for damages when performing judicial functions. However, consistent with Gravel, the Court found in Dennis v. Sparks (1980) that federal judges do not have immunity apart from performing their judicial function; in this case the Court found that federal judges are not immune from conspiracy charges and that co-conspirators cannot be considered "official aides" of a judge. Similarly, in Nixon v. Fitzgerald (1982) the Court defined the range of presidential immunity. Among their findings in this case, the Court determined that presidential aides are entitled to the same absolute immunity granted to congressional aides in Gravel

In many instances Gravel has been invoked to emphasize the limits of immunity under the Speech or Debate Clause. In United States v. Gillok (1980), for instance, the Court ruled that a state senator is not immune from prosecution in a federal court on the basis of the Speech or Debate Clause. Presidents Nixon and Clinton tested the boundaries of presidential immunity only to find that the same limitations found in Gravel applied to the executive branch as well.