Charles Rangel v. John Boehner, 415 U.S. App. D.C. 60

Rangel is a U.S. Representative for New York’s 13th District who faced ethics scrutiny after the 2007 shift to Democratic control of the House.
The House Committee on Ethics investigated multiple alleged improprieties by Rangel.
In November 2010, the adjudicatory subcommittee found clear and convincing evidence of eleven ethical violations.
The Ethics Committee adopted these findings and recommended censure as the punishment.
The House approved the censure by a 333–79 vote, and the censure was read on the floor on December 2, 2010.
Rangel filed suit in district court challenging the censure as violating House Rules and the Fifth Amendment Due Process Clause; the district court dismissed the complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Speech or Debate Clause bars the suit against legislators.	Rangel claims the conduct was legislative but seeks relief for a censure.	Defendants argue the actions are protected legislative acts and immune from suit.	Yes; Speech or Debate Clause bars the action, requiring dismissal.

Gravel v. United States, 408 U.S. 606 (1972) (aides may be protected when performing legislative tasks if doing so would be impossible without them)
Eastland v. U.S. Servicemen’s Fund, 421 U.S. 491 (1975) (absolute immunity extends to legislative acts and purposes)
United States v. Johnson, 383 U.S. 169 (1966) (legislative acts retain immunity regardless of motive)
Kilbourn v. Thompson, 103 U.S. 168 (1880) (defines legislative acts as those generally done in a session of the House)
McMillan v. Brown, 412 U.S. 306 (1973) (conduct of legislative process and staff involvement considered legislative acts)
Eastland v. U.S. Servicemen’s Fund, 421 U.S. 491 (1975) (reiterates broad reach of Speech or Debate Clause to protect legislative processes)