Bogaert v. Land is a federal lawsuit filed on July 18, 2008 in the United States District Court for the Western District of Michigan by Rose Bogaert against Terri Lynn Land in Land's official capacity as Michigan Secretary of State. Bogaert claims that her rights under the U.S. Constitution were violated by MCL 168.957, the Michigan statute that forbids recall signatures to be collected by people who live in a district other than the district of the legislator whose recall is sought. The action filed by Bogaert is a 42 U.S.C. 1983 civil rights action.