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Protection from discrimination in employment on the basis of race, creed, sex, and place of national origin is a fundamental national policy of constitutional dimension.t Congress, however, has consistently exempted itself from its own fair employment laws,2 gaining for itself a reputation as the nation's "last plantation." 3 Extension to congressional employees of the protection from discrimination in employment provided by Title VII of the Civil Rights Act of 19644 is currently under consideration.' Such legislation may conflict with the speech or debate clause of the federal constitution,6 which, as a means of fostering an independent and untramelled legislative process, has traditionally protected individual Senators and Representatives from judicial and executive interference. This Note formulates judicial guidelines for implementing extension of Title VII to Congress in a manner reconciling the competing values of

Title VII and Congressional Employees: The "Chilling Effect" and the Speech or Debate Clause