Americans United for Separation of Church and State

Urgent Message for Churches
Concerning Distribution of "Voter Guides"

Milton Cerny &
Albert G. Lauber, Jr.
Law Offices
Caplin & Drysdale
Chartered
One Thomas Circle, N.W.
Washington, D.C. 20005-5802
202/862-5000


Under Sec. 501(c)(3) of the tax code, charities are absolutely prohibited from intervening in political campaigns by endorsing or opposing candidates for public office. This bar against campaign activities applies with full force to churches. There is no Supreme Court authority, under either the Religion Clauses or the Free Speech Clause of the First Amendment, that confers on churches a blanket exemption from tax-law requirements, such as the prohibition against political intervention, that apply even-handedly to churches and other charities.

IRS rules permit charities, including churches, to engage in nonpartisan voter education activities. As Election Day approaches, the Christian Coalition and other groups may ask churches to distribute "voter guides" to their members, contending that this is a permissible type of voter education. Churches should approach distribution of such voter guides with extreme caution.

Before agreeing to distribute a voter guide prepared by another organization, a church must ensure that the guide is truly nonpartisan and does not endorse or oppose any candidate, either explicitly or by implication. It does not matter that the church may not intend any political intervention. The IRS and the courts do not look to the church's motive, but to whether the voter guide in fact favors one candidate over another.

Election activity by charities, including churches, is currently a subject of intense IRS interest. The IRS recently said that it will have "zero tolerance" for violations, noting that the law "prohibits all forms of participation or intervention in any political campaign," even if the charity's involvement is "subtle" or "inadvertent." Several charities recently lost their tax exemptions for making implied endorsements of political candidates. And in delivering its recent warnings, the IRS specifically cited a case where a church had its exemption revoked for political activity in the 1992 campaign. The consequences of an IRS audit can be severe: even if a church does not lose its exemption and ability to receive deductible contributions, the IRS can impose monetary penalties against the church and its officials.

If a church distributes a partisan voter guide, it will constitute improper political activity by the church, even though someone else prepared the guide. In a recent speech, a high- ranking IRS official warned that the Service will examine all aspects of voter guides for signs of bias, including the array of questions presented, the size of type used for different candidates, and the photographs of candidates themselves. Thus, it is essential that churches consult their legal advisors and carefully review any voter guide before agreeing to distribute it. The fact that the Christian Coalition prepared a voter guide does not ensure that it is nonpartisan. The Christian Coalition is not a Sec. 501(c)(3) charity, and IRS rules thus allow it to engage in some political activity, such as disseminating voter guides that endorse or oppose candidates. By contrast, IRS rules absolutely prohibit a church from distributing a partisan guide.

In the past, the Christian Coalition has reportedly withheld distribution of its voter guides until the last Sunday before the election in order to maximize their impact. This mode of distribution could jeopardize a church's tax-exempt status if it prevents meaningful review of the guide before it is disseminated. Unless a church's legal advisors are given sufficient time to review the voter guide in advance of its distribution, the church will have no way of knowing whether the guide is truly nonpartisan and thus permissible for it to distribute.

The Christian Coalition has not as yet distributed its voter guides for the November 1996 election, and it has refused requests to release them earlier than in past years. Thus, it is not possible to advise pastors now whether these guides will comply with IRS requirements. The Coalition's publication of voter guides in prior elections, however, counsels careful scrutiny of the November 1996 guides when they finally appear. The Federal Election Commission has determined that the Coalition improperly engaged in partisan political activity when distributing voter guides during the 1990, 1992, and 1994 campaigns. Litigation on that subject is now pending in federal court.

The Christian Coalition contends that its voter guides are nonpartisan because they do not expressly endorse candidates and are based on candidates' responses to questionnaires. In fact, the tax rules are not so simple. A voter guide may implicitly favor a candidate even though it does not tell people how to vote or evaluate candidates with "plus" or "minus" signs. The overall content and presentation of the guide must be considered in order to determine whether it is even-handed, neutral, and objective in portraying candidates' positions.

If a voter guide exhibits bias in favor of or against any candidate, the IRS will treat it as electioneering activity, even if the guide disclaims any intent to make endorsements. Whether a voter guide is biased depends on all the facts and circumstances. The following "red flags" may indicate that a voter guide will be viewed as partisan by the IRS:


October 10, 1996


For additional information please contact Joe Conn at Americans United's Communications Department via email at conn@au.org or write us at:

Americans United for Separation of Church and State
1816 Jefferson Place, NW
Washington, D.C. 20036
(202)466-3234 -- (202)466-2587 (fax)

©Americans United for Separation of Church and State, 1996. All rights reserved.

Graphic Rule

Americans United for Separation of Church and State

Legal Requirements for Voter Guides
to Qualify as Permissible Voter Education

Milton Cerny &
Albert G. Lauber, Jr.(1)
Law Offices
Caplin & Drysdale
Chartered
One Thomas Circle, N.W.
Washington, D.C. 20005-5802
202/862-5000

Charitable organizations exempt from federal income tax under section 501(c)(3) of the Internal Revenue Code are absolutely prohibited from participating or intervening in any political campaign on behalf of or in opposition to any candidate. This bar against political intervention applies with equal force to churches and to other charities. There is no Supreme Court authority, under either the Religion Clauses or the Free Speech Clause of the First Amendment, that confers on churches a blanket exemption from tax-law requirements -- such as the prohibition against political intervention -- that apply even-handedly to churches and other charitable organizations.(2)

The tax law defines impermissible "participation" or "intervention" in political campaigns to include the publication or distribution of written statements in support of or in opposition to a candidate. Treas. Reg. Secs. 1.501(c)(3)-1(c)(3)(iii) & 53.4945-3(a)(2)(i). Section 501(c)(3) does not, however, prohibit distribution of voter education materials, provided they are politically neutral. See Rev. Rul. 78-248, 1978-1 C.B. 154. This memorandum is intended to help churches identify voter guides that the IRS will likely view as prohibited campaign intervention, rather than as permissible voter education.

These issues are complex and demand careful consideration. Before distributing any voter guide -- particularly when the guide has been prepared by another organization -- a church should carefully evaluate its content and format to ensure that it complies with IRS requirements. This review should preferably be done in conjunction with legal counsel. This is not an area for quick judgments or casual reliance on the advice of other organizations that may be interested in seeing their guides distributed widely.


A. Reasons for Concern


1. The IRS is watching. Before distributing any voter guide, churches need to be confident that the guide is on the right side of the intervention/education line. Enforcing the prohibition against political activities is a high priority for the IRS, particularly since members of Congress in both political parties have voiced concern about what they see as inappropriate electioneering by tax-exempt organizations.(3) Throughout this campaign year, the Commissioner of Internal Revenue and other senior IRS officials have warned that they take very seriously their obligation to enforce this aspect of the tax law. E.g., IR 96-23 (Apr. 24, 1996). Reinforcing this message, the IRS recently sanctioned a section 501(c)(3) organization for improper intervention in political campaigns. LTR 9635003 (Apr. 19, 1996).


2. The prohibition is absolute. Unlike the flexible limits imposed on lobbying, the prohibition against political campaign activities is absolute. Both the courts and the IRS have held that there is no "de minimis rule" for electioneering: any amount of political intervention, even if insubstantial in the context of the organization's overall operations, constitutes a clear violation of section 501(c)(3).(4) Just last year, the IRS reaffirmed that it will have "zero tolerance" for political intervention by charities. In a memorandum recommending sanctions against an organization whose fundraising activities had crossed the line into political intervention, the IRS stated its position as follows:

Intervention in a political campaign may be subtle or blatant. It may seem to be justified by the press of events. It may even be inadvertent. The law prohibits all forms of participation or intervention in þany' political campaign.
LTR 9609007 (Dec. 6, 1995).


3. A nonpartisan motive is no defense. An organization's motivation for distributing voter guides or other campaign material is not relevant in determining whether the distribution constitutes political intervention. Thus, an organization can violate the prohibition even though it does not intend to endorse or oppose a particular candidate, and even if it is acting for what it regards as moral or religious reasons. In an early pronouncement considering the application of the political campaign prohibition to television broadcasts, the IRS stated that the prohibition covers any "statements made in direct relation to a campaign which affect voter acceptance or rejection of a candidate, without regard to motive." General Counsel Memorandum 35902 (July 15, 1974). The IRS made clear that the tax results of political activity will be determined "not by the motive of the participant but by the consequence, reasonably to be anticipated, of his participation." The IRS has consistently adhered to this position. See Kindell and Reilly, "Election Year Issues," IRS 1992 Exempt Organizations Continuing Professional Education Technical Instruction Program, at 415 ("Kindell and Reilly, 1992 CPE Text").


4. Churches are not immune from scrutiny. Although the Internal Revenue Code provides churches certain procedural protections in the event of an audit (IRC Sec. 7611), the prohibition against political activities applies to churches no less than to other charities. To cite a well-known example, the Church at Pierce Creek recently lost its tax exemption for publishing open letters in newspapers opposing Bill Clinton's candidacy for President in 1992.(5) In another prominent example, the IRS proposed to revoke the tax-exempt status of Jimmy Swaggart Ministries after Reverend Swaggart publicly endorsed Pat Robertson for President.(6) Recent reports indicate that the IRS is now auditing at least 50 tax-exempt organizations with a view to determining whether they engaged in improper political activities.(7) Several of these examinations may involve churches.


5. Material prepared by other organizations may not conform to section 501(c)(3) standards. Churches need to exercise extreme caution when considering distribution of campaign materials prepared by other organizations, which may not be subject to the same prohibition against political activities that applies to churches and other section 501(c)(3) groups. The Christian Coalition, for example, is reported to have applied for exemption under section 501(c)(4) as a "social welfare organization"; such entities are free to engage in some political activity, so long as this is not their primary activity.(8) Churches accordingly need to be aware that, when another organization asks them to distribute campaign-related materials, there is no assurance that these materials will have been prepared according to the nonpartisan standards required of organizations, like churches, that are treated for federal tax purposes as charities.


6. Penalties can be severe. A church that violates the bar against political campaign activities risks revocation of its tax-exempt status, as well as its ability to receive contributions that are tax-deductible by its donors. Many people assume that the IRS would be reluctant to revoke a church's exemption in all but the most extreme circumstances. As noted earlier, this assumption is incorrect: the IRS has taken a variety of enforcement actions against churches engaged in political intervention. Moreover, revocation is not the only sanction available to the IRS. An IRS action to revoke a church's tax exemption may result in a negotiated settlement involving financial sanctions and restrictions on the organization's future activities.

The Internal Revenue Code also imposes monetary penalties on organizations and the officials who work for them if prohibited political activities occur. See IRC Sec. 4955. Under these rules, a church could be subject to a first-tier tax equal to 10% of any amounts spent on prohibited intervention; this tax increases to 100% of the expenditure if the violation is not corrected promptly. Church managers who knowingly approve such expenditures may be individually subject to a 2.5% excise tax, increasing to 50% if the violation is not corrected.


B. Voter Guides: Specific Issues

Organizations sometimes publish voter guides presenting candidates' responses to questionnaires or summaries of their prior voting records. Provided that such guides maintain complete political neutrality, they can serve an appropriate "voter education" function that is consistent with the distributing organization's section 501(c)(3) status. See Rev. Rul. 78-248, 1978-1 C.B. 154. On the other hand, distributing a voter guide that favors one candidate over another -- directly or indirectly -- will constitute political campaign intervention that can jeopardize the distributor's tax-exempt status.

Whether a particular voter guide qualifies as permissible voter education or constitutes prohibited political intervention may well depend on subtle and complex judgments about the overall import of the guide. There are few bright lines in this area. However, it is clear that a voter guide can violate the bar against political activity even though it contains no express statements for or against a particular candidate. See Rev. Rul. 78-248 (Situation 4). Even where a voter guide contains no explicit endorsements, the IRS will examine all the facts and circumstances to determine if the guide's presentation of the candidates' positions could reasonably be expected to influence voters for or against the candidates.(9)

Published rulings and other pronouncements of the Internal Revenue Service indicate that the following "red flags" may cause it to view a voter guide as partisan:


1. Focus on issues tracking an organization's known agenda. The IRS will likely regard a voter guide as campaign intervention if the guide emphasizes candidates' positions on issues that closely track the publishing organization's known positions on those same issues. In Revenue Ruling 78-248, the Service indicated that the nature of the issues addressed in a voter guide -- standing alone -- can cause the guide to violate section 501(c)(3). This ruling provided contrasting examples of voter guides that do, and do not, constitute prohibited political intervention. In the guide that the IRS approved, the issues were selected "solely on the basis of their importance to the electorate as a whole." On the other hand, the guide that focused solely on issues of importance to the distributing organization was deemed to constitute political intervention. According to the IRS, the latter guide's emphasis on issues of concern to the distributing organization showed that its purpose was not nonpartisan voter education, even though the guide contained no express statements in support of or in opposition to any candidate.

The criteria used in selecting issues for inclusion in a voter guide are significant for two reasons. First, a guide that selects issues solely on the basis of their general importance to the electorate as a whole is more apt to be politically neutral because, by definition, the issues are chosen on an objective and nonpartisan basis. Second, when a voter guide concentrates on issues of special importance to the organization that publishes it, this can create the impression that the guide is asking readers to compare the candidates' positions with the organization's own positions. This risk is especially acute when the organization's agenda on the issues presented is highly publicized or readily apparent from the guide itself. In such circumstances, an implicit comparison between the organization's positions and the candidates' positions is unavoidable, and this would likely cause the IRS to find political intervention in violation of section 501(c)(3).

The importance of neutral selection criteria is illustrated by a 1989 IRS legal memorandum with special relevance for religious organizations. See General Counsel Memorandum 39811 (June 30, 1989). This memorandum reports an IRS proposal to revoke the exempt status of a foundation established to promote conservative Christian values, in part because of voter guides it had distributed during an election campaign.(10) Because the guides identified the foundation's religious focus, admonished Christians to vote appropriately, and emphasized issues on which its position was readily apparent -- parents' rights, abortion, ERA, homosexual rights, church school freedom, evolution, creationism, nuclear freeze, state lottery, and legalized prostitution -- the IRS viewed the guides as an attempt to influence the election. This legal memorandum graphically illustrates that a voter guide can violate section 501(c)(3) even though it reports candidates' positions on a fairly broad range of issues, if those issues generally track the organization's own agenda and readers are implicitly invited to compare the organization's positions with those of the candidates.


2. Unfair description of candidate's position. Not surprisingly, another red flag that will cause the IRS to view a voter guide as campaign intervention is any unfairness in the way candidates' positions are described. This concern follows directly from the fundamental requirement that any voter-education activities conducted by section 501(c)(3) organizations must be truly unbiased and nonpartisan. Obviously, any material that unfairly characterizes a candidate's positions could not be described as "unbiased."

The IRS has stated that an important factor in determining whether a publication constitutes political activity is whether it qualifies as "educational" activity within the meaning of section 501(c)(3). See Kindell & Reilly, 1992 CPE Text, at 414. Significant distortions of candidates' views would almost certainly cause a voter guide to fail the "educational" test. In order for a publication to qualify as "educational," it must be aimed at developing the audience's understanding and be free of factual distortions. See Rev. Proc. 86-43, 1986-2 C.B. 729. Purposeful mischaracterization of a candidate's position is plainly inconsistent with these requirements.

Although easy to state in principle, the requirement that a voter guide fairly reflect candidates' positions is often difficult to apply. A candidate's position on an issue may be ambiguous, or the candidate may shift positions subtly over time; assessing how accurately a voter guide depicts the candidate's views may thus require information that is not readily available. For these reasons, the IRS has indicated that it will first consider whether a voter guide simply reprints verbatim candidates' responses to the organization's questionnaire; the IRS is more likely to find political intervention if the organization edits or modifies the candidates' responses or prints fewer than all responses. See Kindell & Reilly, 1992 CPE Text, at 421.

For example, the Christian Coalition typically asks candidates to complete questionnaires containing almost 100 questions, but it selects for inclusion in the voter guide only 6-10 responses that often vary from one electoral district to another. If these responses are chosen with a view to unfairly polarizing the candidates in order to make one candidate appear unacceptable, that would create a serious risk of bias. Bias may also occur if the voter guide omits key qualifying language from a candidate's questionnaire response, portraying the candidate as wholeheartedly "supporting" a position whereas his or her stance is actually more complex. When confronted with a voter guide that appears to do anything more or less than simply reprint candidates' responses to a questionnaire -- in full and as received -- churches need to consider carefully the accuracy, and their ability to assess the accuracy, of the material presented before distributing it.


3. Unfair summary of candidate's voting record. An unbalanced summary of a candidate's voting record creates concerns similar to those raised by potentially misleading descriptions of candidates' questionnaire responses. However, the IRS has noted an additional factor that it will consider in assessing reports of voting records. In Revenue Ruling 80-282, 1980-2 C.B. 178, the IRS noted the "inherent limitations of judging the qualifications of an incumbent on the basis of a few selected votes" and cited with approval an organization's statement to this effect. Churches should be aware that voter guides which use voting records as an index of a candidate's broader views -- as the Christian Coalition's voting guides have previously done -- will likely be scrutinized closely by the IRS for accuracy and bias.


4. Wide distribution close to election. A final "red flag" cited by the IRS is wide distribution of election-related material just prior to Election Day. While this mode of distribution should not cause a truly neutral voter guide to be treated as campaign intervention, it will certainly increase the IRS's level of scrutiny. The IRS has warned that a particular voter guide might be permissible if its distribution were small and not timed to affect the election; but that the same voter guide might be impermissible if its distribution were larger or if the timing suggested an attempt to influence election results. See General Counsel Memorandum 38444 (July 15, 1980).

Thus, all the considerations discussed above assume increased significance when a church is deciding whether or not to distribute a voter guide that is part of a blanket distribution scheduled for the weekend before Election Day.(11) In such circumstances, churches absolutely must make the effort to get the legal advice necessary to determine whether distribution of such a voter guide would be consistent with the church's continued exemption under section 501(c)(3).


Conclusion

Churches, like all section 501(c)(3) organizations, are absolutely barred from intervening in any political campaign on behalf of or in opposition to any candidate for public office. Before agreeing to distribute a voter guide prepared by another organization, a church must ensure that the guide does not transgress this statutory rule. This will require careful review of the voter guide for indications of either explicit or implicit candidate endorsements.

We have prepared this memorandum to serve as a matrix for reviewing voter guides that purport to be nonpartisan. We know that these rules are complex and subtle and that resolution of these questions is not a simple matter. Therefore, we encourage churches to ask their legal advisors for assistance in reviewing voter guides before they are distributed, thus minimizing the risk of jeopardy to their tax-exempt status.
 
 

Footnotes

(1) The authors are partners in the law firm of Caplin & Drysdale, Chtd., Washington, D.C. Mr. Cerny was formerly Chief of the Exempt Organizations Ruling Area at IRS and Technical Advisor to the Assistant Commissioner, Employee Plans and Exempt Organizations. Mr. Lauber previously served as Deputy Solicitor General in the Department of Justice, with principal responsibility for litigating tax cases before the U.S. Supreme Court. Both have written extensively on the issue of nonprofits and electioneering activities.

(2) The Supreme Court has held that a State, consistently with the First Amendment Religion Clauses, may decline to exempt churches from a generally-applicable sales tax, since religious activity is not "being singled out for special and burdensome treatment." Jimmy Swaggart Ministries v. California Board of Equalization, 493 U.S. 378, 390 (1990). The Supreme Court has likewise held that the IRS, consistently with the Religion Clauses, may deny an income tax exemption to religious schools that violate public policies against racial discrimination. Bob Jones University v. United States, 461 U.S. 574, 602-604 (1983). In Christian Echoes Nat'l Ministry v. United States, 470 F.2d 849, 856-857 (10th Cir. 1972), cert. denied, 414 U.S. 864 (1973), the court of appeals explicitly held that the Sec. 501(c)(3) bar against political activities may constitutionally be applied to churches to the same extent as other charities. "Tax exemption is a privilege derived from legislative grace, not a constitutional right." Nationalist Movement v. Commissioner, 102 T.C. 558, 584 (1994). "Since the Government may constitutionally tax the income of religious organizations," it may "grant reasonable exemptions to qualifying organizations while continuing to tax those who fail to meet those qualifications." General Conference of the Free Church v. Commissioner, 71 T.C. 920, 930-931 (1979).

(3) See Margaret M. Richardson, Speech presented to the Association of the Bar of the City of New York, June 11, 1996, reported in Tax Notes Today, June 12, 1996.

(4) United States v. Dykema, 666 F.2d 1096 (7th Cir. 1981); Association of the Bar the of City of New York v. Commissioner, 858 F.2d 876, 880 (2d Cir. 1988), cert. denied, 490 U.S. 1030 (1989). The legislative history underlying the campaign prohibition fully supports this position. See H.R. Rep. No. 91-413, 91st Cong., 1st Sess. 31 (1969); S. Rep. No. 91-552, 91st Cong., 1st Sess. 47 (1969).

(5) See Branch Ministries v. Commissioner, Docket Number 1:95C-V00724 (D.D.C. filed Apr. 17, 1995). See also Christian Echoes Nat'l Ministry v. United States, 470 F.2d 849 (10th Cir. 1972), cert. denied, 414 U.S. 864 (1973).

(6) As a condition of settling the IRS' action, Reverend Swaggart agreed to create a special compliance committee to ensure that no further acts of political intervention would occur. See "Shun Politics, Tax Exempt Groups Told," Los Angeles Times, Page B-5 (Jan. 12, 1992).

(7) Letter from Michael P. Dolan, Deputy Commissioner, IRS to Representative Charles B. Rangel, dated September 17, 1996.

(8) See Treas. Reg. Sec. 1.501(c)(4)-1(a)(2)(ii); Rev. Rul. 81-95, 1981-1 C.B. 332. Published reports indicate that the Christian Coalition applied for tax-exempt status in 1989, apparently under section 501(c)(4), but that it has not yet received a determination from the IRS that it qualifies for tax exemption. See 14 Exempt Organizations Tax Review 372 (Sept. 1996); See also Sabato and Simpson, Dirty Little Secrets 311 (Random House 1996).

(9) See Rev. Rul. 78-248, 1978-1 C.B. 154; Kindell & Reilly, 1992 CPE Text at 410, 415. The fact that a voter guide employs an educational methodology (e.g., in seeking candidate responses to questionnaires) does not mean that it will escape the "political intervention" label. See Association of the Bar of the City of New York, supra (objective rating of judicial candidates); Rev. Rul. 67-71, 1967-1 C.B. 125 (endorsement of state candidates in a school board election).

(10) The identity of the taxpayer is not disclosed in the memorandum. Under the IRS policy in effect at the time, letters revoking tax exemptions were not released to the public.

(11) A recent book by Larry Sabato, a professor at the University of Virginia, and Glenn Simpson, a reporter for the Wall Street Journal, reports Charles Cunningham, voter guide coordinator for the Christian Coalition, as stating that the Coalition withheld distribution of its voter guides in 1994 until the last Sunday before the election in order to maximize their impact. Sabato and Simpson, Dirty Little Secrets 128 (Random House 1996).

 
 
(The authors are partners in the law firm of Caplin & Drysdale, Chtd, Washington, D.C. Mr. Cerny was formerly Chief of the Exempt Organizations Ruling Area at IRS and Technical Advisor to the Assistant Commissioner, Employee Plans and Exempt Organizations. Mr. Lauber previously served as Deputy Solicitor General in the Department of Justice, with principal responsibility for litigating tax cases before the U.S. Supreme Court. Both have written extensively on the issue of nonprofits and electioneering activities.)

For additional information please contact Joe Conn at Americans United's Communications Department via email at conn@au.org or write us at:

Americans United for Separation of Church and State
1816 Jefferson Place, NW
Washington, D.C. 20036
(202)466-3234 -- (202)466-2587 (fax)

©Americans United for Separation of Church and State, 1996. All rights reserved.

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Americans United for Separation of Church and State

Urgent Message To Churches
About Voter Guides

Dear Pastors and Other Religious Leaders: 
Here is some urgent information for American
church leaders.
Two of the most well-respected tax attorneys
in the country have prepared a vital document
concerning the distribution of "voter guides"
in churches. The urgency of this issue cannot
be overestimated.

Courts have never ruled that the First Amendment
permits churches to ignore tax law and conduct
electioneering in their facilities. Distribution
of voter's guides determined to be partisan
(favoring one candidate over another) can lead
to fines against the church or its leaders and
even loss of tax-exempt status. 
Recognizing that there is widespread confusion 
about this issue, Americans United has asked a
leading Washington law firm to prepare an
authoritative analysis of the law. The authors
are Milton Cerny, who was chief of the exempt
organizations ruling branch of the Internal
Revenue Service for eight years, and Albert
G. Lauber Jr., who was deputy solicitor general
of the United States. 
The following material should not be treated
as a substitute for direct legal advice. Please
share this information with your own attorney,
who can guide you through an analysis of the
material you may be asked to disseminate by
groups such as the Christian Coalition.
I hope the following summary is a useful start. 
A more detailed legal memorandum is also available.
It is available at Americans United's website:
http://www.netplexgroup.com/americansunited/ . 
We have gone through a great deal of effort to 
have these documents prepared and to locate people
who could benefit by receiving them. However, if
you would like to have your name removed from our
public service announcement e-mail list, please
let me know and we will remove your address promptly.
On the other hand, please feel free to forward or
otherwise circulate this critical information to
your colleagues, friends and neighbors as needed.
The Rev. Barry W. Lynn, Executive Director
Americans United for Separation of Church and State
1816 Jefferson Place, N.W.
Washington, D.C. 20036
(202) 466-3234

For additional information please contact Joe Conn at Americans United's Communications Department via email at conn@au.org or write us at:

Americans United for Separation of Church and State
1816 Jefferson Place, NW
Washington, D.C. 20036
(202)466-3234 -- (202)466-2587 (fax)

©Americans United for Separation of Church and State, 1996. All rights reserved.

Graphic Rule