The Political Campaign Activity Quick Reference Guide

Case Western Reserve University is committed to the free expression of political views by members of the campus community and to the value of discourse and debate as a critical part of the higher education experience.

CWRU must also comply with rules governing organizations that are tax exempt under Section 501(c) (3) of the Internal Revenue Code:

  1. Tax exempt organizations are prohibited from participating in a political campaign on behalf of or in opposition to any candidate.
  2. Voter education activities that do not show a preference for a particular candidate are generally permissible.
  3. Lobbying Congress or federal officials to influence policy on behalf of CWRU is generally permissible. The vast majority of day-to-day CWRU-federal contacts are not considered lobbying. Pursuant to CWRU policy, lobbying contacts on behalf of CWRU may only be made by the President, Provost, Deans, Vice Presidents, and their designees. These individuals are required by law to report their lobbying activities to the Office of Government Relations. The University follows similar guidelines in recording and reporting State of Ohio government lobbying activities.

Whether an activity is allowable depends on the specific facts involved.  Below we provide general guidance.

Candidates Appearing on Campus

Candidates may be invited to speak on campus provided that an equal opportunity is given to ALL candidates seeking the same office. There may be different events for different candidates, but the events must be comparable in terms of expected attendance. CWRU cannot indicate support or opposition for a particular candidate. Political fundraising is impermissible. All pre-event publicity must include a statement that the views of those invited to speak on campus are the views of the speaker and NOT the views of CWRU; that use of CWRU’s facilities for this event does not constitute an endorsement by CWRU, and that CWRU does not endorse this candidate or any other candidate in connection with this or any other political campaign or election. A candidate may also be invited to speak in a non-candidate capacity, if, for example, he/she holds a public office or is a celebrity. The candidate should not make mention of his/her candidacy and CWRU must maintain a non-partisan atmosphere at the event.

Public Forums or Debates

Public forums and debates are permissible provided that the format does NOT favor a particular candidate (e.g., through biased questioning or the order of presentation). Topics should cover a wide range of issues. The moderator cannot indicate a preference for a particular candidate.

Voter Registration Activities

Voter registration activities are permissible provided that NO reference to a candidate or political party is made by the volunteers staffing the booth or in the materials available at the booth, except for official voter registration forms.

Get Out To Vote Activities

It is permissible to contact people to encourage them to vote. It is NOT permissible to undertake the activity in a way that favors one candidate, such as by stressing the importance of voting only to people who are in favor of one candidate, or by offering transportation to the polls only to people in favor of one candidate.

Individual Activities by CWRU Leadership

CWRU is committed to respecting personal and academic freedom. However, because of CWRU’s status as a tax-exempt organization, those in a leadership position at CWRU can NOT make partisan comments in official CWRU publications or official CWRU meetings or functions.

Endorsements by Individuals in a Leadership Position

A person in a leadership position is permitted to endorse a candidate in an advertisement, provided that the endorsement is clearly made in the leader’s PERSONAL capacity and NOT on behalf of CWRU, the ad is paid by the campaign, is not in an official publication of CWRU, and the ad states that titles (if given) are provided for identification only. A CWRU leader can NOT endorse a candidate in an official CWRU publication, even if the leader pays for the ad him/herself.

Use of CWRU Facilities

Facilities may be made available to candidates ONLY if they are made available to all candidates in the same election on an equal basis. Normal CWRU fees will be charged.

Use of CWRU Email System, Copiers, and Mailing Lists

It is not permissible to use CWRU’s e-mail system, copiers or mailing lists to reproduce or disseminate campaign-related information or literature.

Use of CWRU Letterhead or Logo

CWRU letterhead and logo can NOT be used on any document (hard copy or electronic) intended to support a particular candidate or political party.

CWRU employees

CWRU employees may NOT perform tasks to support a particular candidate or political party during working hours, unless performed during permissible and available vacation or leave time taken in accordance with CWRU policy.

CWRU Web Sites and Web Links

CWRU websites may NOT be used to support a particular candidate. Web links from CWRU websites may be made ONLY to nonpartisan voter education sites. Web links may NOT be made to sites that favor one particular candidate.

CWRU’s Tax Exemption

CWRU’s tax exemption cannot be used to purchase goods or services to be used to support a particular candidate or political party.

Student Activities

Student organizations may advocate publicly for a particular candidate, provided that the student organization clearly identifies itself as a student organization that does not represent the official views of Case Western Reserve University. (For further information on student activities, see “Guidelines for Student Organizations Conducting Political Activity on Campus”.) Administrators and faculty must be careful to avoid the appearance that CWRU is endorsing the activity.

Issue Advocacy

Activities related to issues, rather than to specific candidates, may or may NOT be permissible. The context must be reviewed to determine if support for the issue implies a suggestion to vote for a particular candidate, e.g., if the issue is a prominent issue that distinguishes the candidates.

For further information or if you have questions about particular activities, please contact Office of Government Relations at 216.368.1723 or Office of General Counsel at 216.368.4286

References: Internal Revenue Service Rev. Ruling 2007-41; American Council on Education: “Political Campaign-Related Activities of and at Colleges and Universities” (prepared by Hogan Lovells US LLP, September 2011).

This policy is subject to the Freedom of Expression / Expressive Activities Policy and its procedures and operating rules.