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 | firstname.lastname@example.org
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.
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.
Voter education activities including voter registration, voter guides, get out the vote
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.
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.
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.
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 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.