I've been following this a bit and it sounds to me that your position is that a state employee is not permitted to make a 'personal' recommendation at all, at least not in any meaningful way.
If 'personal' recommendations are regulated by the state, how can they be really be 'personal'?
Not if the recommendation is based on race or religious beliefs and the person making the recommendation is a state employee using his title and letterhead of the state run university. I don't see what is 'personal' about that. If he wanted to make a recommendation unrelated to his state job and without using his state given title, then it is his choice. But as it is, he is using his title to give credence to this recommendation, so it is not 'personal'.