Following the resolution of the 16-day government shutdown, U.S. Representative Justin Amash, a libertarian Republican representing Michigan's third district, has

acquired a primary challenger.

A leading opponent of the surveillance programs of the NSA, Amash also received notoriety earlier this year for being allegedly "purged" from his place on the House Budget Committee for not voting with the party frequently enough. He also became one of the faces of the tea party-led government shutdown. He ultimately voted against the bill that ended the shutdown.

The Justin Amash primary challenger is Brian Ellis, the owner of a capital management firm. The early noises emanating from the Ellis campaign suggests that the businessman intends to challenge Amash from the right and to portray the congressman as insufficiently conservative.

In his press release, Ellis says he is a "fiscal and social conservative Republican who embraces traditional values, limited government, and strong national security."

He also says that Amash has turned his back on conservative principles, specifically for voting "present" on the Keystone XL Pipeline and on defunding Planned Parenthood.

Criticism for Amash voting "present" is nothing new and is a tactic he utilizes when he personally supports a measure, but considers it unconstitutional.

The congressman was disparaged by several for not supporting the House GOP's attempt to defund NPR in 2011. Amash explained his decision then that the bill only sought to defund NPR, not public broadcasting in general.

He explained that instead, the bill "takes aim at one particular private entity" solely "because that entity is unpopular."

Similarly, Amash says he supports the construction of the pipeline, but according to a spokesman, opposed "the singling out of any one company or individual in a bill."

Although Ellis announced his candidacy on October 8, the business community's interest in ousting Amash predates the government shutdown.

from October 6, business leaders were already looking for a possible rival, indicating they prefer someone who can work the "inside game" and "gain influence" for the district.

According to a Washington Post report

Another issue that could arise for Amash is fundraising. Near the end of the quarterly reporting period, Amash announced on his Facebook page that he needed over $12,000 to reach his quarterly minimum. Through the 2012 elections, Amash's fundraising has relied mainly on individual contributions large and small.

According to OpenSecrets.org, 95 percent of Amash's contributions came from individual donors. He may need that to continue: the latest reporting shows that Amash received zero funds from the National Republican Congressional Committee, the main fundraising arm of the House GOP. Yet, while it appears Amash will be getting little financial support from the party, he did have the biggest quarter of any of the so-called dissident in the party: $207,884.

Also working in Amash's favor is the district's reputation as a center for grassroots support. In the 2012 presidential primary with Mitt Romney, a native son on the ballot, but also the perceived establishment candidate, the third district supported Rick Santorum. An Amash supporter quoted in the Post said, "[The power brokers] can put all the money they want into it and find somebody to run, but they won't beat Justin because he's got the grass roots."