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 | 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. 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.

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; 6) Candidate requests to rent space.

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 to 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 their 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.

Political event requests sponsored by student organizations should originate in the Student Center & Activities Office.  Student Center & Activities staff will assist all student organizations in the preparation and implementation of their politically- based programs. 

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 their 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, 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 made to the 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 the 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 much 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 of any modifications to podiums or lecterns used during an event, and will avoid using or including other University materials with the University trademark.

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 may want to make appearances at St. Catherine University. St. Catherine University is a private institution surrounded by public streets and byways. The University reserves the right to remove, or contract with appropriate authorities to remove, any individual or individuals who either threaten the safety of, or actively harm, any member of the campus community or guests of the University while on its property. 

Candidates seeking access to St. Catherine property are required to have a confirmed appointment. Candidates who want to visit campus must contact the Office of University Events to submit their request. 

Once an appointment is scheduled, St. Catherine University staff will assist candidates in identifying a designated space in the atrium of the Coeur de Catherine building. 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 permitted to bring and distribute materials at the time of their scheduled appointment. Candidates may not use or distribute any materials with the St. Catherine University logo and/or brand incorporated. 

Candidates are allowed to enter residence halls and apartments, with approval. 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.