Connecticut Catholic Public Affairs Conference

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GUIDELINES FOR PARISH INVOLVEMENT IN      

 POLITICAL ACTIVITIES

The Church’s Role in Politics

The Church has both a duty and a right to call attention to the moral and religious dimensions of public issues.  As it does this, it applies Gospel values as a norm against which social policies and political activities are measured.  It also shares its vision of how our call, as believing Christians, compels us to work for the transformation of society in ways that make it more just. 

For reasons that are both theological and legal, the Church’s involvement in public life does not extend to endorsing candidates for election to public office nor calling for their defeat.

The Church is permitted, however, to instruct the faithful at any time about the Church’s teaching on moral and social issues, and identify such issues as important current political topics.

The Legal Basics

As a 501(c)(3) organization, the Church is prohibited by the Internal Revenue Code from participating or intervening in any political campaign on behalf of, or in opposition to, any candidate for public office.  There is no safe harbor of permissible intervention; the ban is absolute.  Any amount of participation in a political campaign, no matter how slight, can put the tax exempt status of the Church in jeopardy.

Churches and church organizations may not endorse or state their opposition to political candidates, including the publishing or distribution of materials that favor one candidate over another.  Nor may churches or church organizations contribute to political candidates or parties, even in the form of in-kind expenditures such as donations of facilities, supplies, or employee time.  Restrictions on political activity apply in equal force to web sites and email as well as more traditional forums.

In addition to the limitations imposed under IRC 501(c)(3), the Federal Election Campaign Act forbids nonprofit entities to work in concert or cooperation with any federal candidate or campaign committee in the development or distribution of campaign materials.


Permissible Church Activities 

 

  • Endorsing/opposing legislation, including ballot referenda
  • Homilies/bulletin inserts on moral issues, and on the moral responsibilities of voters
  • Providing educational materials on public policy issues, but not candidates, to parishioners
  • Arranging for groups to meet with their elected officials to advocate for or against legislation
  • Encouraging letter-writing, phone calls and other contacts with candidates and elected officials about issues
  • Inviting all candidates for public office to a Church-sponsored public forum, debate, or candidates’ night
  • Conducting a nonpartisan voter registration drive on Church property.
  • Distributing unbiased candidate voting records on a wide variety of issues

 

Prohibited Church Activities

  • Endorsing/opposing candidates for political office
  • Homilies/bulletin inserts regarding specific candidates
  • Distributing or permitting distribution of partisan campaign literature under Church auspices or on Church property
  • Arranging for groups to work for a candidate for public office
  • Funding or financial support of any candidate, political action committee, or political party
  • Inviting only selected candidates to address your Church-sponsored group, or permitting/hosting political meetings on Church property
  • Conducting voter registration that is slanted toward one party
  • Rating candidates numerically, or “favorably” or “unfavorably”
  • Sharing parish resources, including mailing lists, with political campaigns or parties

Specific Situations

Voter-Registration Drives.  Parishes provide an ideal setting for voter-registration efforts, which encourage citizens to embrace their right and duty to share in the political life of our state and our country.  Citizens who are registered to vote likely will vote and, in preparing to cast ballots, will become more aware of important policy issues, including those that impact the poorest and most vulnerable members of their communities.  Parishes and other Catholic organizations can sponsor voter-registration drives, provided that no bias for or against any candidate, political party, or voting position is evidenced.  Such bias would be indicated by distribution of partisan literature or materials indicating the Church’s position on issues during connection with the registration drive, by targeting drives toward individuals who support the Church’s positions or a particular candidate or party, or by coordinating the drive with candidates or their committees.  Voter-registration efforts by Catholic entities should not be conducted:  (1) in cooperation with any political campaign, (2) according to the identity of the candidates, (3) based upon a candidate’s or party’s agreement or disagreement with Church positions, or (4) in a matter targeting members of a particular party.

Candidate Appearances.  In an election year, candidates for public office seek occasions to promote their campaigns before large audiences.  Some candidates view parish gatherings as especially attractive opportunities.  The following guidelines should be helpful to parishes and other Church organizations as they assess the appropriateness of candidates’ requests to speak at Church events.

1) Candidates should never be permitted to speak in connection with Mass or any other religious service.  If a candidate seeks to do so, deny permission, citing Internal Revenue Service (IRS) regulations governing political activity of tax-exempt religious organizations.  You might also advise that religious services are inappropriate occasions for partisan policies.

2) A candidate for a given office should not be permitted to address an event sponsored by a Church organization (e.g., parish committee meeting, Knights of Columbus gathering, or alumni Communion breakfast), unless all other candidates for that office have been invited to make a presentation at the same event.

3) A parish official may introduce a public-office holder to participants in an event sponsored by a Church organization, but not in that person’s capacity as a candidate.  Thus, a senator or congressman may be recognized as “Senator” or “Representative,” but not as a candidate for reelection to the U.S. Senate or House of Representatives.

4) A public figure or expert in a given field who is also a candidate for public office may be allowed to speak as a public figure or expert without providing equal access to other candidates.  However, the following precautions must be taken in order not to violate IRS rules:

          a)  the person must speak only in his or her capacity as expert or public figure;

          b)  no mention may be made of his or her candidacy;

          c)   no campaign activity may occur in connection with the appearance; and

          d)  all communications, oral or written, should identify the other-than-candidate capacity in which the       
               individual is appearing and should not mention his or her candidacy.  The IRS has made clear that if the
               primary purpose of the invitation is to showcase an individuals’ candidacy, the organization may violate
               election rules even if no campaign activity occurs.  Prior to any appearance, an invited speaker who is also a
               candidate for public office should be informed in writing of the sole purpose of the appearance (viz, as an
               expert or public figure).

Candidate Forums.  A candidate forum can be a very helpful source of information about candidates for parishioners and others in the community.  They have been sponsored very successfully by dioceses, parishes, and other Catholic organizations throughout the country.  However, it is important to understand the legal framework within which these activities must take place.  Like all Church-sponsored political activities, candidate forums must be completely non-partisan.  Guidelines that must be followed include:

1) Invite all candidates in a given race and treat them alike:  This includes invitations and follow-up, the information provided to them in advance, the questions they are asked, and the opportunities they have to respond.

2) Do not intervene, directly or indirectly, in the campaign on behalf of, or in opposition to, a particular candidate or party:  Nothing done at the forum can show preference for one candidate over another.  The moderator must be unbiased.  Carefully worded questions should be prepared in advance.  If questions are permitted from audience members, they should be written on index cards and screened before being read by the moderator.

3) Cover a broad range of issues:  Focusing on one issue will create the appearance of endorsing some candidates over others.  A broader focus will educate voters on the candidates’ respective positions and avoid any appearance of bias.

4) Do not allow candidates to distribute campaign material during the forum:  Campaign signs, placards, brochures, or other material supplied by candidates, their parties, their supporters, or their opponents should not be displayed or distributed on the property of the entity hosting the forum.

Leafleting in the Parking lots.  The parking lots of most Catholic churches and other Catholic entities are classified as private property.  They do not qualify as public forums to which First Amendment free speech protections attach.  Parishes should not authorize the distribution of partisan campaign materials or biased voter-education materials in the lot.  Parking lots are distinguishable from public streets and sidewalks adjacent to Church facilities.  These spaces generally are classified as public property over which the organization lacks control over access.

Outside Voter Guides.  Catholic entities should be wary of non-diocesan groups that seek to distribute their own voter-education materials on Church property or through Church channels.  The preparation, content, format, and presentation of these materials may not satisfy the legal requirements applicable to Catholic organizations.  Often, the organizations preparing these materials may not even be subject to the same rules governing tax-exempt organizations.  The fact that it may be permissible for the preparing organization to distribute a voter guide does not make it appropriate for Church entities to do so.  Parishes and other Catholic organizations should not distribute any “outside voter guides” unless they are specifically authorized by the Connecticut Catholic Conference.

The Connecticut Catholic Public Affairs Conference staff is available to assist you with questions regarding participating in political activities.  Please call (860) 524-7882 or send an e-mail message to ccc@ctcatholic.org.

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Connecticut Catholic Public Affairs Conference | 134 Farmington Avenue, Hartford, CT 06105| (860) 524-7882