BEFORE THE

FEDERAL ELECTION COMMISSION

,
Complainant,
v.
Terri Lynn Land
7955 Byron Station Court SW
Byron Center, MI 49315
Terri Lynn Land Ior Senate and Kathy Vosburg, Treasurer
P.O. Box 308
Grandville, MI 49418
Respondents.
COMPLAINT
Complainant Iiles this complaint under 2 U.S.C. 437g(a)(1) against Terri Lynn Land,
Terri Lynn Land Ior Senate ('the Committee) and Kathy Vosburg in her oIIicial capacity as
Treasurer (collectively, 'Respondents), Ior violations oI the Federal Election Campaign Act
('Act), as described below. Complainant alleges that the Committee did not pay Iair market
value Ior transportation services and thus received in-kind contributions in excess oI the legally
permitted limit.
A. FACTS
Terri Lynn Land became a candidate Ior the U.S. Senate in Michigan on July 1, 2013. In
recent news reports, the Committee has claimed use oI two Foiu Inteinational CXT tiucks foi
tianspoitation anu auveitising puiposes. The assesseu value of these tiucks accoiuing to
auto assessment websites ranges Irom $93,000-$115,000
1
. This vehicle is not currently available
to the public Ior rent.
The Iirst publicly available documentation oI the Committee`s use oI these trucks was on
July 4, 2013 according to the Committee`s oIIicial Facebook account. The screen shot Irom said
account below is photographic evidence conIirming the use oI the trucks including political
advertisements the Committee attached to the trucks.

According to the Committee`s FEC Iilings, the Committee began paying Ms. Land`s brother
in law, Mr. Roger Lucas, in January oI 2014 Ior use oI the truck. Over the course seven
months, the Committee paid $7,000 to Mr. Lucas directly. The corresponding chart includes the
disbursements taken directly Irom the Committee`s FEC Iilings.
1
http://www.topspeed.com/trucks/truck-reviews/international/index778.html
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PAYEE P0RP0SE BATE AN00NT PAuE
L0CAS, R0uER TR0CK RENTAL 1114 $1,uuu
L0CAS, R0uER TR0CK RENTAL 2114 $1,uuu
L0CAS, R0uER TR0CK RENTAL S114 $1,uuu
L0CAS, R0uER TR0CK RENTAL 4114 $1,uuu Page 667
L0CAS, R0uER TR0CK RENTAL S114 $1,uuu Page 667
L0CAS, R0uER TR0CK RENTAL 6114 $1,uuu Page 668
L0CAS, R0uER EQ0IPNENT RENTAL: TR0CK 7114 $1,uuu page 84
|FEC.gov, accesseu 81814j
The Committee claims no disbursements to Mr. Lucas Ior use oI the trucks beIore
January 2014. This would indicate that the Committee paid $7,000 Ior use oI these trucks Ior at
least 13 months as we have documented above. Thus, the average monthly rate paid by the
campaign per truck to-date is $269.23.
In publisheu iepoits, foimei FEC geneial counsel Laiiy Noble has saiu that "For
most things you look at Iair market value.II you're going to rent the campaign a car, look at
what campaign would have to pay at arm's length Ior that car.
Since the Committee is leasing the vehicle Irom a private, Iamily source and, since there
is no publicly available inIormation Ior a Iair markejt value lease oI such a vehicle, it is not
possible to ascertain an approximate price Ior such a vehicle lease or rental. But a truck oI this
size and oI its nature would logically seem to cost more than a standard lease Ior a standard
pick up truck since the maker describes this truck as 'the World`s Largest Pick Up Truck. The
average price Ior leasing a truck in the range oI the International CXT would clearly be above
$269.23 per month. Estimates oI a lease Ior a much smaller pick up truck range Irom $750 to
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over $1,000 according to publicly available documents. Thus, the Iair market value oI the trucks
in question is at least $750 per truck per month.
Additionally, Mr. Lucas has donated $2,600 to the Committee Ior the primary election
and $2,600 to the Committee Ior the general election. This represents the maximum $5,200
permissible under Federal Election Commission contribution limits.
It is important to note that neither Mr. Lucas, nor the committee, has reported any in kind
contributions between Mr. Lucas and the Committee.
B. LEGAL ARGUMENT
Federal law permits candidate committees to accept up to $2,600 Irom each individual
Ior each election.
2
Mr. Lucas has donated $2,600 to the Committee Ior the primary election and
$2,600 to the Committee Ior the general election. The Committee has been using these trucks
speciIically Ior campaign purposes Ior at least 13 months and paying below market rates to a
Iamily member who owns the trucks. The true Iair market value oI the usage oI two trucks is at
the very least approximately $19,500 Ior the months in which the Committee has utilized them.
These costs, less the disbursements already paid by the Committee ($7,000) show clearly that the
$12,500 diIIerence in paid disbursements and actually Iair market value is violation oI the limits
an individual can give Ior each election. Additionally, the Committee has already accepted the
$5,200 maximum donation Irom Mr. Lucas. At this point, the Committee is in violation oI the
law by accepting a $12,500 in kind donation Irom Mr. Lucas, which is also $12,500 over the
limits oI the law.
C. REQUESTED ACTION
2
2 U.S.C. 441a(a)(1)(A).
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As we have shown, there is substantial evidence that Respondents have violated the Act.
We respectIully request the Commission to investigate these violations, including whether they
were knowing and willIul. Should the Commission determine that Respondents have violated
the Act, we request that Respondents be enjoined Irom Iurther violations and be Iined the
maximum amount permitted by law.
Sincerely,
_______________________
SUBSCRIBED AND SWORN to beIore me this day oI .

Notary Public
My Commission Expires:

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