[ Footnote 14 ] It is worth nothing that the Rules of the Senate forbid disparagement of other Members on the floor. Senate Rule XIX （Apr. 1979）。 See also T. Jefferson， A Manual of Parliamentary Practice 40-41 （1854）， reprinted in The Complete Jefferson 714-715 （S. Padover ed. 1943）。

　　[ Footnote 15 ] Provision for the use of the frank， 39 U.S.C. 3210， does not alter our conclusion. Congress， by granting franking privileges， stationery allowances， and facilities to record speeches and statements for radio broadcast cannot expand the scope of the Speech or Debate Clause to render immune all that emanates via such helpful facilities.

　　[ Footnote 16 ] Neither the District Court nor the Court of Appeals considered whether the New York Times standard can apply to an individual defendant rather than to a media defendant. At oral argument， counsel for Hutchinson stated that he had not conceded that the New York Times [443 U.S. 111， 134] standard applied. Tr. of Oral Arg. 18. This Court has never decided the question； our conclusion that Hutchinson is not a public figure makes it unnecessary to do so in this case.

　　MR. JUSTICE BRENNAN， dissenting.

　　I disagree with the Court's conclusion that Senator Proxmire's newsletters and press releases fall outside the protection of the speech-or-debate immunity. In my view， public criticism by legislators of unnecessary governmental expenditures， whatever its form， is a legislative act shielded by the Speech or Debate Clause. I would affirm the judgment below for the reasons expressed in my dissent in Gravel v. United States， 408 U.S. 606， 648 （1972）。 [443 U.S. 111， 137]