The court of appeals affirmed district court orders denying a criminal defendant’s motions for relief premised on the Speech or Debate Clause. The court held that neither the federal Constitution’s Speech nor the Debate Clause shielded from criminal responsibility a congressman’s quid pro quo offer to support future public land exchange legislation if private parties would purchase land owned by the congressman’s former business partner.

Former Arizona Congressman Richard D. Renzi was indicted by grand jury for his alleged involvement in a quid pro quo deal that he offered to two private parties. According to the indictment, a copper mining firm sought private property to purchase so that it could offer the property to the government in exchange for certain surface rights in support of planned mining operations. The firm approached Renzi about developing and sponsoring the necessary land exchange legislation. At that time Renzi was a member of the House Natural Resources Committee, which was responsible for approving any land exchange legislation before passing it to the House.