Political Campaigns and Political Activities

St. Mary’s, as a Catholic and Marianist University, is responsible for engaging people in dialogue around difficult questions of faith and culture. St. Mary’s encourages students, faculty, and staff to become involved in the political process through holding educational events on campus such as voter registration drives conducted in a non-partisan manner, candidate debates, and other voter education activities. Members of the University community are free to exercise their rights as citizens and to be politically active, either individually or through groups and organizations.

Political campaigns and political activities are essentially the support for or opposition to a candidate for office at the federal, state or local level even if the candidate is not affiliated with a party. The following guidelines are to serve as guidance to all University employees and students with regard to participating in political campaigns and political activities.

St. Mary’s University is the possessor of considerable material resources, which have been acquired in part through its status as a tax-exempt institution of higher learning. This tax-exempt status is based on the institution’s fulfillment of the requirements set forth in part in Section 501(c)(3) of the Internal Revenue Code, which provides in effect that an educational institution qualifies for tax exemption as a recipient of deductible contributions provided that:

• “no substantial part of the activities (of the Institution) is carrying on propaganda, or otherwise attempting to influence legislation” and
• the institution “does not participate in, or intervene in (including publishing and distributing statements), any political campaign on behalf of (or in opposition to) any candidate for public office.”

St. Mary’s must safeguard its tax-exempt status by establishing guidelines for those University community members wishing to exercise their right to participate in political activities on or off campus. All institutions exempt under Section 501(c)(3) are prohibited from directly or indirectly participating in or intervening in any political campaigns and/or political activities on behalf of (or in opposition to) any candidate for elective public office. Therefore, engaging in impermissible political campaigns and/or activities can result in the revocation of the University’s tax-exempt status. There is no restriction of the discussion of political issues or the teaching of political techniques, nor are academic endeavors that address public policy issues affected.

Permissible Activities

Certain political campaigns and/or political activities are permissible under Section 501(c)(3). These activities, however, must be educational in that they present a sufficiently full and fair picture of the facts and permit individuals to form independent opinions or conclusions about the candidates for elective public office. Examples of political campaigns and/or political activities that may be permissible include:

Provide a Forum for Candidate Debates

if the following criteria are followed:

• Debate must be open to all legal candidates for the contested office.
• The questions presented to the candidates should be composed by an independent, non-partisan group and a moderator should be selected by the sponsoring organization and their role should be limited to ensuring the debate ground rules are followed and topics cover a broad range of issues.
• The debate should begin and end with the following statement. The views presented are solely those of the speaker(s) and do not represent the views of St. Mary’s University. The University neither supports nor opposes the candidates and/or parties mentioned within the provided remarks.
• No campaign fundraising may take place on University property.

Student Newspapers and their Accompanying Websites

must follow the following criteria:

• Editorials must clearly state that the views reflected are those of the student editors and not the University.
• These University operations may not accept paid political advertising by candidates.

Voter Registration

may be conducted if the following guidelines are met:

• Voter registration drives must be conducted in a non-partisan manner. No partisan campaign signs, banners or posters are permitted in the area where the drive is being conducted.
• The University must ensure that any voter guides distributed present all of the candidates and their views/responses in a non-partisan manner. This is true for both University-prepared and third-party prepared materials.

Curricular Activities

• The University recognizes presentations by official political candidates may also be a relevant component of its educational mission. Official candidates may be invited to speak to a faculty member’s class, in a non-candidate capacity, provided that the individual is chosen to speak solely for the reasons other than his or her candidacy, the individual speaks only in his or her non-candidacy capacity, no reference to the election is made, and a non-partisan atmosphere is maintained in the classroom. Classes are not open to the public and would occur without notification to the media.
• Students may earn course credit for participation in political campaigns, provided such participation is an integral part of a particular class and all students in that class are permitted to work for a campaign of their choice.

Co-curricular Activities

• Registered Student Organizations (RSO) may participate in a political campaign on behalf of any candidate for public office or ballot issue if their campus-based activities comply with: a) University policies and procedures, including these guidelines; b) the student organization clearly identifies itself as a Registered Student Organization and the RSO does not represent the official views of St. Mary’s University. (See addendum on RSO) Notification to the public or to the media would only be allowed if the events and/or activities are permissible, by this policy, and they are facilitated through the Office of University Communications.
• The University may post employment, internship and service opportunities for students affiliated with partisan organizations and/or campaigns.

University leaders, employees and students are encouraged to express their views and support candidates for elective public office in an individual capacity.

• In the event a University employee provides oral or written support/opposition to a candidate – and – where there is a reasonable perception that the writer/speaker may be closely identified with the University, the following disclaimer language should be made a conspicuous portion of the oral or written remarks: The views presented are solely those of the author (speaker) and do not represent the views of St. Mary’s University. The University neither supports nor opposes the candidates and/or parties mentioned within the provided remarks.

Non-permissible Activities

• Activities in or outside of the classroom that favor or oppose one or more candidates for public office.
• The use of University monies and resources to provide funding or logistical support for political campaigns and/or political activities, such as advertising, attendance at campaign events, and other forms of advocacy. The restriction extends to the posting, or transmission, of campaign-related materials over the Internet.
• Public statements of position (oral or written) made by or on behalf of the University in favor or opposition to a candidate for elective public office.
• The University’s information technology resources may not be used to support or oppose a candidate’s campaign. Individuals cannot use official University-hosted websites to express their views on a candidate unless that expression meets the “educational activities” test as defined as permissible under Section 501(c)(3) of the Internal Revenue Code. Employees and students are allowed to link a University website to official candidate websites provided that links to all qualified candidates are equally accessible and the links are provided as a means of voter education and not advocacy.
• The University will not recognize student organizations created solely for the purpose of advocating for the election of a political candidate (e.g. Students for Candidate X) or ballot initiative.
• Distributing statements through University-sponsored or financed means that are prepared by others that favor or oppose a candidate.
• Voter education or registration drives conducted in a biased manner that favor or oppose candidates or specific political parties.
• Political advertising in official public spaces on campus or/in University buildings. The University cannot indicate any support for a candidate with signs, banners, stickers, etc. in an official public space on campus. This includes all administrative and academic buildings where University business is conducted.
• Students may post signs in their residence hall rooms in compliance with University and residence hall policies. However, the public areas of the residence halls are considered official public spaces and must remain free of political campaign advertising.
• Door-to-door campaigning in the residence halls or in official public spaces on campus.
• The use of any University resources, including rental or other use of facilities, to campaign or to assist a campaign.
• Making telephone calls to the public advocating for or in opposition to a candidate or political party in the name of St. Mary’s University.
• University-paid political advertisements (e.g. newspapers, radio, television, web sites, mailings, campus signs, etc.).
• No advertisements or editorials regarding candidates for elective public office may be placed in official University publications, with some exception for student newspapers and their accompanying websites (see Permissible Activities).
• With regard to referendum ballot issues, it is the proper role of community members to discuss the underlying issues and share information using University resources. However, community members are respectfully asked to avoid using campus-wide communications systems and assets (including, but not limited to: print, email, University webpages, bulletin boards) for overt electioneering and dissemination of partisan information related to the issue. To balance the priority of open dialogue with regard to public matters, those community members who wish to engage in partisan advocacy of issues are asked to use their own personal email accounts, blogs and webpages.

Hosting of Political Candidates Actively Running for Office

The challenges and issues facing our nation are topics worthy of debate on a university campus, which welcomes the free exchange of ideas. While the University will not, nor is it permitted to, endorse or appear to endorse specific candidates due to its status as a 501(c)(3) nonprofit institution of higher education, student groups, faculty, and staff may seek to bring official candidates to campus either through established and topical University programs and conferences, such as the Conference for Justice and Social Concerns, Lin Great Speakers Series and Community Conversations, or in debate settings.

All proposed visits must be submitted in a timely manner to the appropriate Dean and/or Vice President for consideration and a determination made on an individual basis as to its logistical and security needs, as well as its impact on the operations of the University. The Office of the President will confer with the appropriate Dean and/or Vice President, considering the proposal, to ensure candidate visits meet guidelines set herein, as well as to ensure the safe and proper setting for the event. (Faculty members who invite political candidates to their regularly scheduled classroom for educational purposes are exempt from this requirement, since these activities occur without notification to the media and to the public, and require no reservation of a public campus space.)

In addition, during a campaign and electoral season, individuals, departments, and groups affiliated or not affiliated with the University may receive requests for candidates to appear on campus. All such requests should be forwarded to the Office of the President.

Employees’ and students’ cooperation is essential to assure that St. Mary’s University remains in compliance with federal requirements and that members of the community act in accordance with the University’s mission. Any political activity, even those sponsored by campus-based organizations, including Registered Student Organizations, may be terminated immediately if found in violation of the above guidelines or other University policies and procedures.