Hutchinson v. Proxmire

The Supreme Court ruled that a speech made on the floor of the Senate cannot be protected under the Speech or Debate Clause if it is reprinted in the form of a newsletter, an interview, or a release to the media. The decision reaffirmed the rule set down in Gravel v. United States regarding the nature of official communication.

In the mid-1970s, Senator William Proxmire became well-known for his "Golden Fleece of the Month Award." This dubious honor was given to persons and institutions whom the senator believed had wasted taxpayer money on ridiculous or unnecessary projects. In April of 1975, Proxmire gave one of these awards to Dr. Ronald Hutchinson of the National Science Foundation, for his research into the ways animals deal with stress. In a speech on the floor of the Senate, Proxmire ridiculed Hutchinson's work as the study of why monkeys "grind their teeth." This speech was protected under the Speech or Debate Clause of the U.S. Constitution, meaning Hutchinson could not sue Proxmire for libel.

However, Proxmire kept up his barrage against Hutchinson outside the Senate floor. He sent a newsletter to his constituents touting the Golden Fleece Award, issued a press release on the subject, and spoke about it in a television interview. In these communications, Proxmire referred to Hutchinson's work as "monkey business" and urged Congress to "put a stop to the bite Hutchinson and the bureaucrats who fund him have been taking out of the taxpayer." Hutchinson sued Proxmire for damages, claiming that Proxmire's remarks had damaged his professional reputation and hindered his ability to make a living as a scientist.