Political Activity

Approved by:  Office of Student Affairs

History:  Revised: January 2012

Related Policies:  N/A

Related Forms, Procedures and References:  N/A

For Questions Contact:  Office of Student Affairs | 651.690.6778 | studentaffairs@stkate.edu

Index: Permissible Political Activities | Candidate Speaking or Participation as non-candidate | Business Activity |Attribution of Individual Activities | Guidelines for Political Candidates Appearing on Campus to Campaign


St. Catherine University (the university) is a 501(c) (3) charitable organization and will not participate or intervene in political campaign activity in support of, or in opposition to, any candidate for public office. IRS rules and regulations prohibit the university from endorsing candidates, making campaign contributions, engaging in fundraising, making statements of position, verbal or written, made on behalf of the institution in favor or opposition to any candidate, becoming involved in any other activity that might be beneficial or detrimental to any candidate, including activities encouraging an individual to vote for or against a candidate based on partisan criteria or host a debate or forum showing preference for or against a certain candidate.

Section 501(c) (3) contains an absolute prohibition on participation or intervention in political campaign activities in support or in opposition to candidates. Violating this prohibition subjects St. Catherine to revocation of its tax exempt status and the imposition of excise tax penalties. For this policy, a candidate is defined as an individual who offers herself or himself as a contestant for an elective public office, whether such office is national, state or local. Section 501(c)(3) defines participation in a political campaign as including the publishing or distribution of statements.

Permissible Political Activities
Some activities are permissible under Section 501(c)(3) as “educational” activities. The regulations allow activities to occur if they present a “sufficiently full and fair exposition of the pertinent facts.” The presentation of information must not be biased and must “permit an individual or the public to form an independent opinion or conclusion.”

Examples of permissible activities are explicated in several non-discrete categories including: 1) Voter Education, Voter Registration, Voter Guides and Get-Out-the-Vote Drives; 2) Organizational Leaders and Political Activity; 3) Candidate Speaking as Candidate; 4) Candidates in Public Forum or Debate; and 5) Candidate Speaking or Participating as Non-Candidate.
 
1.      Voter Education, Voter Registration, Voter Guides and Get-Out-the-Vote Drives.

Voter education activities including voter registration, voter guides, get out the vote
drives and public forums,when conducted in an unbiased manner, are permissible political activity and essential to the student learning experience.
 
The Federal Election Commission provides guidance on conducting a nonpartisan voter registration campaign. Its regulations require that either all candidates or no candidates be named, that all or no party affiliations be given, and all persons interested in registering be permitted to do so regardless of their party preference. The organization conducting voter registration must be a university office, department, or a chartered student organization. The organization must use the required process to reserve space/table. The organization must conduct voter registration in a non-partisan manner.

Preparing or distributing voter guides may violate IRS regulations if the guide focuses on one issue, a narrow range of issues or if the guide reflects bias, especially in close proximity of an election. Questions in voter guides should be clear and unbiased with regard to content and structure and uniform to the questions posed to candidates. Candidates should be given reasonable time to respond to the questions. Candidates choices should not be narrow or limited and candidates should be given reasonable time to explain her/his position. Content of the guide should closely resemble the candidates response. Candidate responses should be subject to minimal editing. All eligible candidates should be given equal opportunity to be represented in the voter guide and the number of issues should fairly represent the range of issues considered by the entire electorate.
 

If the university distributes a voter guide published by another entity, it assumes responsibility for ensuring compliance with IRS regulations.

2.       Organizational Leaders and Political Activity
 

Consistent with the federal and state requirements, university leaders retain individual rights of free expression. Speaking or communicating in a partisan fashion, at an official university event or in a university publication, violates the political campaign intervention prohibition.

3.      Candidate Speaking as Candidate
 
Candidates for public office may be invited to, or may seek permission to visit, the campus to make public appearances in connection with their campaigns. If a candidate uses a campus visit as an occasion to make a campaign speech, the campus organization hosting the event should make it clear that the institution does not support or oppose the candidate in all promotional materials related to the event, and state the following: “Views expressed by political candidates are not endorsed by St. Catherine University.” This disclaimer must be stated again when introducing the candidate at a public forum as well as at the close of the forum. Absolutely no political fund-raising is allowed.
 
4.       Candidate in Public Forums and Debates
 
The university may provide forums for candidate debates. All debates and forums will be conducted in an unbiased manner and provide candidates equal opportunity to participate. 
 
The following factors should be considered in determining whether a debate is a permissible political activity:
a.) The questions presented to the candidates should be prepared by an independent and nonpartisan panel.
 
b.) The debate topics should cover a broad range of issues, including but not limited to
those issues of importance to the organization sponsoring the debate.
 
c.) A moderator should be selected by the sponsoring organization and his or her role should be limited to ensuring that the debate ground rules are followed. The moderator should refrain from commenting on the candidates’ statements in a way that demonstrates approval or disapproval of their ideas.
 
d.) The debate should begin and end with a clear statement to the effect that the views presented are those of the candidates and not of the sponsoring organization (e.g. “Views expressed by political candidates are not endorsed by St. Catherine University.”).
 

5.     Candidate Speaking or Participating as Non-Candidate

Candidates for public office may also be invited to speak at either campus in their individual capacities as a non-candidate. For example, an incumbent state governor running for re-election, who is also an alumn,may be invited to speak in her capacity as an alumnae without the activity constituting an impermissible political activity. During the speech, no reference should be made to the governor’s status as a candidate for public office nor should any campaign activity occur in concurrence with the speech. Any promotional material related to the speech should make clear that the governor is appearing in her capacity as an alumna, without any mention of her candidacy for re-election.
 

A candidate may also choose to appear on campus at an event open to the public. If the candidate is asked to speak or be recognized at the event, the university must ensure that: the candidate was selected for reasons other than status as a candidate or public office official; she speaks only in a non-candidate capacity; no mention is made of her status as a public official or candidate; no campaign activity occurs in relationship to the appearance; and the university must maintain a nonpartisan atmosphere during the event.

 
Business Activity
St. Catherine may make facilities available to individuals or groups who wish to use them to conduct political campaign activities. The institution should ensure that all facilities are made available to political groups on the same basis as to other non-political groups or individuals. If fees are normally charged, they should also be charged to the political group or candidate. No preferential treatment should be given. All provisions associated with establishing permissible political activity must also be considered and satisfied when
determining appropriateness of any business or rental activities and throughout any event considered business activity.
 
Attribution of Individual Activities to Section 501(c)(3) Organizations
Faculty and staff members may serve as advisors to candidates, and may even run for office themselves. Where such participation is undertaken solely in an individual capacity, without making any use of the resources of the institution, the activity should not be attributed to the institution for purposes of the prohibition on political campaign participation.
 
Guidelines for Political Candidates Appearing on Campus to Campaign
The St. Catherine community supports civic engagement, in part, by providing access to our campuses for political candidates. For the purpose of these guidelines, a candidate is defined as the individual running for public office and does not include staff of the candidate.
 
Candidates running for public office, including, but not limited to Congress, the governor’s office, or Minnesota Legislature, may want to make appearances at St. Kate’s. Candidates, in addition to the above opportunities, and may wish to walk around our campuses or enter our facilities.
 
Candidates seeking access to St. Catherine property are required to make an  appointment 48 hours prior to the visit. Candidates who want to visit either campus must contact the Office of Student Affairs (651.690.6778) to submit their request.

Once an appointment is scheduled, candidates will be allowed to distribute campaign literature in the atrium of Coeur de Catherine (St. Paul campus), the Deli (Minneapolis campus) or in designated public spaces outside.
 
Candidates are only allowed to enter classrooms if the approved appointment explicitly identifies the classroom and if the faculty member of record has agreed.

Candidates are allowed to enter residence halls and apartments, with approval, but are limited to only the designated lobby or commons area. Candidates are explicitly prohibited from entering the personal dwelling unit of all residence halls and apartments.