Approved by: Office of Student Affairs
History: Revised: July 2021
Related Policies: N/A
Related Forms, Procedures and References: Political Activity Request Form
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. Internal Revenue Service (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. Violating this statute subjects St. Catherine University to potential 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 themselves 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; 6) Candidate requests to rent space.
NOTE: During the COVID-19 pandemic and related public health restrictions, requested in-person political activity may reasonably be limited.
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.
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.
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, a, a candidate running for public office may be invited to speak in their capacity outside their candidacy without the activity constituting an impermissible political activity. During the speech, no reference should be candidate’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 speaker is appearing in their specific capacity, without any mention of candidacy for public office.
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;
- the candidate speaks only in a non-candidate capacity;
- no mention is made of their 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.
6. Candidate Requests to Rent Space
Candidates for local, state, and national offices who officially have filed in Minnesota may request to have a forum on campus. When considering the request, University officials will take into account ongoing operations and previously scheduled demands on space, time and other resources. Please note that St. Catherine University will not relocate scheduled classes nor cancel pre-existing and planned scheduled events in order to accommodate candidate requests.
Candidates will cover their own travel expenses, costs of all security and any other associated costs. Candidates will pay the rental fee for use of St. Catherine University facilities, as well as costs associated with use of the facility.
Any images or photography taken may not include use of the St. Catherine University trademark, and all images must be free of St. Catherine University branding. Candidates will cover the cost to modifications to podiums or lecterns used during an event, and will avoid using or including other University materials with the University trademark.
Once an appointment is scheduled, St. Catherine University staff will assist candidates in identifying a designated space in the atrium of Coeur de Catherine building, beginning no earlier than 10:00am and ending no later than 6:00pm.
Candidates are allowed to enter residence halls and apartments, with approval, but are limited to only the designated lobby or commons area, beginning no earlier than 10:00am and ending no later than 7:00pm. Candidates are explicitly prohibited from entering the personal dwelling unit of all residence halls and apartments. Candidates must present reasonable and proper identification in order to gain access to campus residential buildings.
Upon approval to visit campus, the Office of Student Affairs and the Department of Public Safety must receive details regarding the candidate’s visit to campus, including staff or companions coming to campus with the candidate and/or any personal security details. The Director of Public Safety or their designee will serve as the primary contact regarding security issues for political candidate events and be responsible for determining and coordinating necessary safety planning and staffing.