FEDERAL ELECTION COMMISSION

Washington, D.C. 20463

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

FAIRPAC (f/k/a John Linder for Congress) 

 and Matthew John Linder, in his official capacity 

 as treasurer

John Linder

)

) 

) 

) 

) 

)

MUR 7578 

STATEMENT OF REASONS OF CHAIR SHANA M. BROUSSARD AND 

COMMISSIONERS STEVEN T. WALTHER AND ELLEN L. WEINTRAUB

This matter involves allegations that former Representative John Linder, who retired in 

2011, made personal use of funds contributed to his principal campaign committee in violation 

of the Federal Election Campaign Act of 1971, as amended (the “Act”) and Commission 

regulations. 

John Linder served as a Representative from 1993 to 2011; Linder for Congress was his 

principal campaign committee.

1

 In January 2014, Linder for Congress was converted to a multicandidate committee named FAIRPAC.2

 At the time of this conversion, $430,622 in leftover 

campaign funds were transferred to FAIRPAC.3

 FAIRPAC has not raised any additional 

contributions since 2014. 

The Complaint alleged that a number of disbursements made between 2014-2018 were 

for personal use, including a $900 payment to the Chowder & Marching Club for dinner and 

1

 Resp. at 1 (April 22, 2019).

2

 Id. 

3

 Linder for Congress 2013 Year-End Report at 4 (Jan. 30, 2014); FAIRPAC Second Amended 2014 April 

Quarterly Report at 2 (July 13, 2014). Since the conversion to a multi-candidate committee, FAIRPAC has received 

a small amount of additional funds in the total amount of $2,529. See FAIRPAC 2019 Year-End Report at 6 (Jan. 

31, 2020) (disclosing $238 in other receipts); FAIRPAC Amended 2018 April Quarterly Report at 6 (Aug. 30, 2018) 

(disclosing $717 in other receipts); FAIRPAC 30 Day Post-Gen. Report at 6 (Dec. 2, 2014) (disclosing $1,574 in 

offsets to operating expenditures). 

MUR757800001
MUR 7578 (FAIRPAC, et al.)

Statement of Reasons

Page 2 of 2

payments for airfare and hotels. The Chowder & Marching Club is a social organization with 

membership limited to current and former Republican members of the House of 

Representatives.4 

While campaign funds generally cannot be used to pay for dues at country clubs and 

other non-political organizations, candidates or federal officeholders may pay membership dues 

in an organization that has political interests “in order to maintain political contacts with 

constituents or the business community.”5 However, the Commission has concluded that a longretired former congressman could not use leftover campaign funds to pay membership fees at the 

Capitol Hill Club, an organization that has political interests.

6

 Given that Linder has not been a 

candidate or officeholder since 2011, there appears to be reason to believe that the payments to 

for Linder’s attendance at the Chowder & Marching Club were impermissible personal expenses 

that would exist irrespective of Linder’s former campaign or duties as a former federal 

officeholder. 

These payments, however, were made more than five years ago, and the applicable 

statute of limitations for the payment of civil monetary penalties has expired. Accordingly, we

voted to approve the Office of General Counsel’s recommendation to dismiss these allegations.7

____________________ __________________________ 

Date Shana M. Broussard 

Chair

____________________ __________________________ 

Date Steven T. Walther 

Commissioner

 November 15, 2021 __________________________ 

 Date Ellen L. Weintraub 

Commissioner

4 Resp. at 9.

5

 Explanation and Justification for Expenditures; Reports by Political Committees; Personal Use of 

Campaign Funds, 60 Fed. Reg. 7,862, 7,866 (Feb. 9, 1995); see also 11 C.F.R. § 113.1(g)(1)(i)(G). 

6 Factual & Legal Analysis at 10-11, MUR 7292 (Stearns). 

7

 Certification, MUR 7578 (FAIRPAC, et al.) (Sept. 30, 2021). We also voted to approve the Office of 

General Counsel’s recommendations to dismiss the other allegations on substantive grounds. Id.; Factual & Legal 

Analysis, MUR 7578 (FAIRPAC, et al.).

November 15, 2021

November 15, 2021

MUR757800002