FEDERAL ELECTION COMMISSION

 WASHINGTON, D.C. 20463 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Jeff Coleman for Congress, Inc., et. al. ) MUR 7679 and 7695 

 ) 

 

STATEMENT OF REASONS OF VICE CHAIR ALLEN DICKERSON AND 

COMMISSIONERS SEAN J. COOKSEY AND JAMES E. “TREY” TRAINOR, III

In these matters, we voted to approve the Office of General Counsel’s (“OGC”) 

recommendation to dismiss the allegations that Coleman Worldwide Moving, LLC and Coleman 

American Moving Services, Inc. violated 52 U.S.C. § 30118 by making in-kind contributions. We 

further voted to approve OGC’s recommendation to dismiss the allegations that Jeff Coleman, Jeff 

Coleman for Congress, Inc., and Joseph Johnson in his official capacity as treasurer, violated 52 

U.S.C. 18 §§ 30116(f) and 30118 by accepting in-kind contributions. We opposed, however, the 

issuance of caution letters to the Respondents. 

For the purposes of 52 U.S.C. § 30109(a)(8), we attach our proposed Factual and Legal 

Analysis in these matters. 

__________________________________ December 3, 2021 

Allen Dickerson Date

Vice Chair

_________________________________ December 3, 2021 

Sean J. Cooksey Date

Commissioner

_________________________________ December 3, 2021 

James E. “Trey” Trainor, III Date

Commissioner

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FEDERAL ELECTION COMMISSION

FACTUAL AND LEGAL ANALYSIS

RESPONDENTS: Jeffrey Coleman MURs: 7679 and 7695

Jeff Coleman for Congress, Inc. and 

Joseph Johnson, in his official capacity 

as treasurer

Coleman Worldwide Moving, LLC 

Coleman American Moving Services, Inc.

I. INTRODUCTION

These two complaints allege Coleman Worldwide Moving, LLC and its subsidiary 

Coleman American Moving Services, Inc. (collectively, “Coleman Moving”) made prohibited 

in-kind contributions to congressional candidate Jeff Coleman and his authorized committee, Jeff 

Coleman for Congress, Inc. and Joseph Johnson, in his official capacity as treasurer (the 

“Committee”). Specifically, the Complaints allege that Coleman Moving allowed the 

Committee to use its trucks and semitrailers as billboards to display large pictures of Coleman, 

his campaign logo, and the campaign’s website address throughout Alabama’s Second 

Congressional District, without compensation. The Complaints also allege that Coleman 

Moving did not receive payment from the Committee for allowing the Committee to use its 

trucks, which prominently displayed the company’s logo and trademark, in the Committee’s 

television and online advertisements, including on the Committee’s Facebook page and YouTube 

channel. 

The available information is insufficient to support the allegations that the Committee 

failed to pay the fair market value for the trucks that it leased to use as billboards. Furthermore,

the value of any in-kind contribution to the Committee that might have resulted from the 

appearance of trucks with the Coleman Moving logo and trademark in the Committee’s 

advertisements would be difficult to quantify and likely de minimis. 

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Therefore, the Commission exercises its prosecutorial discretion and dismisses the 

allegations that Coleman Worldwide Moving, LLC and Coleman American Moving Services, 

Inc. made prohibited in-kind contributions in violation of 52 U.S.C. § 30118, and that Jeff 

Coleman and Jeff Coleman for Congress, Inc. and Joseph Johnson in his official capacity as 

treasurer accepted the in-kind contributions in violation of 52 U.S.C. §§ 30116(f) and 30118.1

II. FACTUAL AND LEGAL ANALYSIS

A. Facts

Jeff Coleman is the current Chairman of Coleman Worldwide Moving, a moving and 

shipping company, and its subsidiary, Coleman American Moving Services, Inc., which owns a 

large fleet of trucks and l8-wheel trailers.2 While serving as chairman of these companies, 

Coleman became a candidate in Alabama’s Second Congressional District, and his authorized 

committee filed its Statement of Organization on August 14, 2019.3 The Complaints allege that 

Coleman Moving made a prohibited in-kind contribution to the Committee by allowing it to use 

Coleman Moving trucks and equipment free of charge. Specifically, they alleged that the 

Coleman Moving trucks and trailers were “wrapped” with the candidate’s picture, campaign 

logo, and campaign messaging and stationed throughout the Second Congressional District.4 

The Complaint in MUR 7679 further alleges that the Committee used Coleman Moving boxstyle moving trucks featuring the Committee’s logo, Coleman’s picture, and Coleman’s 

1

 See Heckler v. Chaney, 470 U.S. 821, 831 (1985).

2

 Coleman Worldwide Moving is an agent of the Allied Van Lines international shipping and moving 

company. See https://www.colemanallied.com/. Coleman lost the July 14, 2020, Republican primary runoff 

election. 

3

 See FEC Form 1, Jeff Coleman for Congress, Inc., Statement of Organization (Aug. 14, 2019), 

https://docquery.fec.gov/pdf/996/201908149162868996/201908149162868996.pdf. 

4

 MUR 7679 Compl. at 1; MUR 7695 Compl. at 1. The Complaints attach pictures of these trucks and 

trailers. MUR 7679 Compl. at Attach; MUR 7695 Compl. at Attach.

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campaign messaging in a series of parades in the Fall of 2019 and that the Committee publicized 

these appearances on its Facebook page.5

 

The Complaints surmise that the trucks and trailers used as billboards belonged to 

Coleman Moving because Coleman is Coleman Moving’s Chairman.6 MUR 7679 also alleges 

that some of the vehicles in question had mud flaps with the Coleman Moving name on them.7 

The Complaints thus allege that because the trucks and trailers are not Coleman’s personal 

property, the Committee’s use of Coleman Moving trucks and trailers without compensation 

constitutes an in-kind corporate contribution from Coleman Moving.8 In further support of these 

allegations, the MUR 7695 complaint points out that the Committee’s FEC reports disclose no 

payments to Coleman Moving for the use of its trucks and trailers.9 

Additionally, the MUR 7679 complaint alleges that the Committee violated the Act by 

airing campaign advertisements on television and Facebook that featured Coleman Moving 

trucks with the company logo and trademark.10 Complainant asserts the use of the Coleman 

Moving trucks in the Committee’s television and online advertisements without compensation 

resulted in an in-kind contribution to the Committee.11 In response to this particular allegation, 

5

 MUR 7679 Compl. at 1. The Complaint attaches pictures of the moving truck it alleges was shown on the 

Committee’s Facebook page.

6

 MUR 7679 Compl. at 1; MUR 7695 Compl. at 1. 

7

 MUR 7679 Compl. at 1, Attach.

8

 MUR 7679 Compl. at 1; MUR 7695 Compl. at 1. 

9

 See MUR 7695 Compl. at 1. 

10 Id. at 2-3. See www.Facebook.com/JeffColemanAL/ (posted Nov. 4, 2019) (Coleman Facebook Page). 

The Complaint does not provide information as to how often or for how long the television advertisements aired. 

According to the information provided by Facebook and YouTube archives, the online ads began airing October 22, 

2019.

11 Id. 

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Respondents do not specifically address whether Coleman Moving owned the trucks or facilities 

seen in the videos, instead, the company simply states that it “was not involved in the creation of 

Mr. Coleman’s campaign materials and advertisements.”12 

The Committee placed at least ten online ads on its Facebook and YouTube pages.13 

Most of the ads were 30 seconds long, a few of which used images of trucks with the Coleman 

Moving trademark and logo.14 The Committee also created a 30-second ad and a 2 1⁄2 minute 

biographical ad that featured the Coleman Moving trucks more prominently, and included 

Coleman discussing his family history and his leadership of Coleman Trucking. The online 

archive shows that starting in late October 2019, the Committee spent a total of $38,495 for its 

Facebook ads and approximately $21,700 for ads that aired on its YouTube page, for a total of 

$60,195; these expenditures were disclosed in the Committee’s Pre-Primary Report.15 A review 

of Federal Communication Commission filings shows the Committee spent $63,215 on 

television advertising in August – December 2019 in the Montgomery-Selma Markets.16

12 Coleman Moving Resp. at 4 (Mar. 13, 2020).

13 See https://transparencyreport.google.com/political-ads/advertiser/AR62103852710625280; 

https://www.youtube.com/watch?v=XxgajipRDNk, (Google archive); 

https://www.facebook.com/ads/library/?active_status=inactive&ad_type=political_and_issue_ads&country=US&im

pression_search_field=has_impressions_lifetime&view_all_page_id=111891756832652&sort_data[direction]=desc

&sort_data[mode]=relevancy_monthly_grouped, (Facebook archive).

14 The 30 second ads titled, “Businessman, not a Politician” and “Business Guy” use the image of an antique 

Coleman Moving truck for less than 5 seconds. However, the 30 second “Safe” and “Movin’ and Shakin’” as well 

as the 2 1⁄2 minute “Movers and Shakers” ads use images of the antique and newer Coleman Moving trucks more 

prominently. See Coleman Facebook Page; see also

https://www.youtube.com/channel/UCiO6m15nuyoVSfhvlfjh0rg/videos (Coleman YouTube Page).

15 See Google archive, Facebook archive. From August 14, 2019 to February 12, 2020, the Committee 

reported disbursing $621,947 to Flexpoint Media, Inc. and $197,065 to Strategic Perceptions, Inc. for “Media 

Placement” as well as $2,078 to I360 LLC and $28,182 to IMGE LLC for “Digital Services.” See

https://www.fec.gov/data/committee/C00715698/?tab=spending. 

16 Federal Communications Commission databases, https://www.fcc.gov/licensing-databases/search-fccdatabases. 

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The Committee and Coleman Moving deny all allegations in the Complaints.17 

Respondents state that the trucks and trailers that the Committee used as billboards for its 

campaign advertisements were leased from The Eagle Leasing Company (“Eagle Leasing”), not 

Coleman Moving.18 The Committee asserts that its lease with Eagle Leasing was made in the 

usual and ordinary course of business, and at fair market rates.19 It further states that its 

disbursements to Eagle Leasing were timely disclosed on the Committee’s Pre-Primary Election 

Report filed with the Commission, which lists two disbursements totaling $18,620 on January 

30, 2020, for “Equipment Leasing.”20 Accordingly, Respondents assert, there was no in-kind 

contribution from Coleman Moving to the Committee.21

Respondents also contend that the Committee’s use of Coleman Moving trucks in its 

television and online advertising was a part of Coleman’s biographical background and not an inkind contribution from Coleman Moving to the Committee.22 Respondents assert that in its 

17 Committee Resp. (Mar. 13, 2020); Coleman Moving Resp. 

18 Committee Resp. at 2; Coleman Moving Resp. at 2.

19 Both the Committee and Coleman Moving Responses state, “Eagle Leasing, Inc. sells trailers identical to 

the ones shown in both Complaints. Their website is https://www.eagleleasing.com/.” See Committee Resp. at 2, n. 

8; Coleman Moving Resp. at 2, n. 7. It is not clear why Respondents reference www.eagleleasing.com, a storage 

container and trailer rental company based in Massachusetts, instead of Eagle Leasing, Inc. in Alabama, which the 

Committee listed in its report to the Commission. The Massachusetts and Alabama companies are separate entities, 

and Coleman and Coleman Worldwide are directly linked to the Alabama company that purportedly provided the 

trailers. See http://arcsos.state.al.us/cgi/corpdetail.mbr/detail?corp=110399&page=name&file=&type=ALL&status=ALL&place=ALL&c

ity=. See also https://www.buzzfile.com/property/100-Eagle-Ridge-Dr-Midland-City-AL/AB0FC42FA8. The 

Alabama Eagle Leasing is located at the same physical address as Coleman Worldwide and Jeff Coleman is listed as 

a registered agent and corporate officer for Eagle Leasing of Alabama.

20 Committee Resp. at 2; Coleman Moving Resp. at 2. See Jeff Coleman for Congress Year End Report 

(Jan. 31, 2020) (reporting the transaction as a debt), 

https://docquery.fec.gov/pdf/418/202001319184773418/202001319184773418.pdf. See also Jeff Coleman for 

Congress Pre-Primary Report at 62, 71 (Feb. 20, 2020), (reporting the payment of the debt), 

https://docquery.fec.gov/pdf/156/202002209186912156/202002209186912156.pdf. The first disbursement was for 

$7,448 and the second disbursement was for $11,172. Id. 

21 Committee Resp. at 2; Coleman Moving Resp. at 2.

22 Id. at 3; Coleman Moving Resp. at 3-4.

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advertisement, Coleman trucks are used in the context of discussing Coleman’s family history in 

the trucking business, the years Coleman worked for the family company, and the success of the 

company during Coleman’s tenure as CEO.23 Respondents argue that the statements by 

Coleman in those advertisements, “My mom and dad started their life together in this truck,” “I 

started working when I was ten,” and “Our revenues have increased ten-fold [when I was CEO]” 

were focused on Coleman’s biography and made no mention of a corporate endorsement or a 

solicitation for funds.24 Respondents further contend that even if the mention of Coleman 

Moving and use of its trucks in campaign advertising were viewed as an in-kind contribution, the 

value associated with it would be de minimis and therefore the allegations should be dismissed.25 

B. Analysis 

The Act and Commission regulations define “contribution” as “any gift, subscription, 

loan, advance, or deposit of money or anything of value made by any person for the purpose of 

influencing any election for Federal office.”26 “Anything of value” includes in-kind 

contributions, such as the provision of goods or services without charge or at a charge that is less 

than the usual and normal charge.27 Commission regulations define “usual and normal charge” 

as the price of goods in the commercially reasonable rate prevailing at the time the services were 

23 Id.; Coleman Moving Resp. at 3-4. See also “Jeff Coleman for Congress” Political Advertisement, 

Facebook, available at Coleman Facebook Page.

24 Id.; Coleman Moving Resp. at 3-4.

25 Committee Resp. at 3; Coleman Moving Resp. at 3-4. 

26 52 U.S.C. § 30101(8)(A)(i).

27 See 11 C.F.R. § 100.52(d)(1). 

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rendered.”28 If a committee pays fair market value for a good or service, then it is not considered 

a contribution.29 

The Act prohibits a corporation from making contributions to federal candidates and their 

authorized committees.30 Officers and directors of corporations may not consent to any 

contribution prohibited by section 30118(a).31 Correspondingly, federal candidates and their 

authorized committees may not knowingly accept a corporate contribution.32 The Commission 

has previously determined that a corporation’s name, trade name, trademarks, and service marks 

are things of value owned by the corporation, and that authorizing a committee to use them may 

constitute an in-kind contribution.33 

The available information is insufficient to support a reasonable inference that the 

Committee paid Eagle Leasing less than fair market value to rent the trucks the Committee used. 

The Complaints do not specify when the Coleman trailer billboards appeared, but the available 

information shows that in late October 2019, the Committee began posting ads on its Facebook 

page depicting local events and featuring images of the Coleman campaign trailer billboards.34 

The Committee reported a debt to Eagle Leasing for equipment rental on its 2019 Year-End 

28 See 11 C.F.R. § 100.52(d)(2).

29 Id. 

30 52 U.S.C. § 30118(a). 

31 Id. 

32 Id. 

33 See Factual and Legal Analysis at 6, MUR 7508 (Friends of Sherrod Brown, et al.) (“F&LA”) (citing 

F&LA at 4, MUR 7302 (Tom Campbell for North Dakota, et al.), Advisory Op. 2007-10 (Reyes); F&LA at 7, MUR 

6542 (Mullin for Congress); F&LA at 10-11, MUR 6110 (Obama Victory Fund)).

34 See Coleman Facebook Page.

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Report which would cover the October 2019 timeframe, and subsequently it reported making 

disbursements totaling $18,620 to Eagle Leasing of Alabama on January 30, 2020.35 

Neither the Complaints nor available information indicate that amounts paid were less 

than fair market value.36 The available information indicates that the Committee paid for certain 

truck rentals; the Respondents deny the allegation that the Committee paid less than fair market 

rate; the Commission is aware of no information to the contrary; and the Committee timely 

reported the debt to Eagle Leasing on its Year End Report and payments to Eagle Leasing on its 

Pre-Primary Reports. Thus, the Commission dismisses the allegation that the Committee 

received these rentals for free or at a reduced price. 

Similarly, for the reasons that follow, the Commission dismisses the allegation that the 

Committee used Coleman Moving’s logo and its trucks as in the YouTube and Facebook 

advertisements. An investigation would be necessary to determine the value of any such in-kind 

contribution, and, consistent with the handling of similar cases, the Commission concludes that 

doing so here would not be a prudent use of its limited resources. 

In several prior matters, the Commission has exercised its discretion and dismissed 

allegations that the presence of a corporate logo or image in a campaign advertisement resulted 

in an in-kind contribution, either because the value of the contribution was de minimis or too 

difficult to calculate.37 

35 Jeff Coleman for Congress, Inc. 2020 Pre-Primary Report at 62, 71 (Feb. 20, 2020), 

https://docquery.fec.gov/pdf/156/202002209186912156/202002209186912156.pdf. 

36 See n. 20, infra. 

37 See First Gen. Counsel’s Rpt. at 20, MUR 6110 (Obama Victory Fund) (dismissed use of corporate names 

and logos to solicit contributions in connection with joint fundraising concert where the companies did not 

contribute directly to the committee or pay costs of the event, the event was modest, and the value of the names and 

logos was not substantial). See also, MUR 7302 (Tom Campbell for North Dakota); MUR 6542 (Mullin for 

Congress) (dismissal of allegations that the committee accepted prohibited in-kind corporate contributions where 

committee paid for video advertisements that featured name and logo of the candidate’s business); MUR 6322 

(Tommy Sowers) (Commission examined use of a corporate logo on a fundraising invitation for an event that served 

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Additionally, the Commission has permitted candidates to discuss their prior business 

experience, even when it involved the use of company logos, in connection with their campaigns. 

In MUR 6542 (Mullin), the Commission dismissed allegations of in-kind contributions from the 

candidate’s business, Mullin Plumbing, where the campaign committee used images and footage 

of the Mullin Plumbing’s name, employees, facilities, and the committee included several photos 

of Mullin Plumbing trucks in its television and YouTube ads that featured Mullin interacting 

with uniformed Mullin Plumbing employees while standing in front of Mullin Plumbing 

buildings and trucks.38 Similarly, in MUR 7302 (Tom Campbell for North Dakota) the 

Commission dismissed allegations regarding the committee’s ads that featured Campbell 

standing in front of a truck with the “Campbell Farms” logo on one of the truck’s windows as he 

discussed his experience as a potato farmer and his plans for the state, and the committee did not 

list any contributions from Campbell Farms-Big Lake in its disclosures.39 In both matters, the 

Commission reasoned that the value of any in-kind contributions from the corporations was 

likely to be de minimis and concluded that pursuing the matters further would not have been a 

prudent use of the Commission’s resources.40 

as both a campaign event for the candidate and a product launch for a corporation that was unrelated to the 

candidate, but dismissed allegations as a matter of prosecutorial discretion); MUR 5691 (Whalen) (finding no inkind contribution to Whalen’s committee from his restaurant chain because an advertisement created by the 

company failed to meet the content prong of the coordination test, even though it used images of Whalen and themes 

similar to those used by his campaign, but failed to expressly advocate Whalen’s election). MURs 6287, 6288, and 

6297 (Liberatore for Congress); MUR 6331 (Comm. to Elect Shirley Gibson for Congress). 

38 Factual and Legal Analysis at 6-7, MUR 6542 (Mullin). 

39 Campbell Farms-Big Lake is a North Dakota partnership that operates a commercial potato farm, for which 

state records showed that Tom Campbell was the registered agent. Factual and Legal Analysis at 2-3, MUR 7302 

(Tom Campbell for North Dakota).

40 See Factual and Legal Analysis at 7-8, 9-10, MUR 6542 (Mullin), Factual and Legal Analysis at 5-6, MUR 

7302 (Tom Campbell for North Dakota). 

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The circumstances here are similar to those past precedents. As with MURs 6542 and 

7302, the potential in-kind contributions here could result from the use of Coleman Moving 

trucks and/or the use of the Coleman Moving logo in the Committee’s online advertisements. 

The trucks are primarily used as Coleman is discussing his family’s history in the trucking 

business and his accomplishments as CEO to explain his background and qualifications for the 

office he is seeking. It would be difficult to determine the precise value of any in-kind 

contribution that might have resulted from Coleman Moving allowing its logo to be used in 

YouTube and Facebook ads featuring its Chairman. 

Accordingly, the Commission exercises its prosecutorial discretion and dismisses 

allegations that Coleman Worldwide Moving, LLC and Coleman American Moving Services, 

Inc. violated 52 U.S.C. § 30118 by making in-kind contributions to the Committee. The 

Commission also dismisses allegations that Jeff Coleman and Jeff Coleman for Congress, Inc. 

and Joseph Johnson in his official capacity as treasurer, violated 52 U.S.C. §§ 30116(f) and 

30118 by accepting corporate in-kind contributions from Coleman Moving. 

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