 The Court has twice considered the role of the Clause in the prosecution of federal members of Congress for bribery under § 201 . In United States v. Brewster ( 1972 ) , the Court held that a § 201 prosecution of a Congressperson does not violate the Clause so long as " no inquiry into legislative acts or motivation for legislative acts is necessary for the Government to make out a prima facie case . " Brewster reinstated a dismissed § 201 indictment because the crime of bribery is complete once the bribe is accepted , whether or not the official performs the promised act . In United States v. Helstoski ( 1979 ) , the Court held that the prosecution may not introduce any evidence of a past " legislative act " at trial . According to Weeks , " [ a ] s a practical matter , it is extremely difficult to successfully prosecute a section 201 action if reference to a defendant 's legislative acts is forbidden . " 
