standardize a two-step process for Senate elections. In the first step, each chamber of the state legislature would meet separately to vote. The following day, the chambers would meet in "joint assembly" to assess the results, and if a majority in both chambers had voted for the same person, he would be elected. If not, the joint assembly would vote for a senator, with each member receiving a vote. If no person received a majority, the joint assembly was required to keep convening every day to take at least one vote until a senator was elected. Nevertheless, between 1891 and 1905, 46 elections were deadlocked across 20 states; in one extreme example, a Senate seat for Delaware went unfilled from 1899 until 1903. The business of holding elections also caused great disruption in the state legislatures, with a full third of the Oregon House of Representatives choosing not to swear the oath of office in 1897 due to a dispute over an open Senate seat. The result was that Oregon's legislature was unable to pass legislation that year. Zywicki again argues that this was not a serious issue. Deadlocks were a problem, but they were the exception rather than the norm; many legislatures did not deadlock over elections at all. Most of those that did in the 19th century were the newly admitted western states, which suffered from "inexperienced legislatures and weak party discipline... as western legislatures gained experience, deadlocks became less frequent." While Utah suffered from deadlocks in 1897 and 1899, they became what Zywicki refers to as "a good teaching experience", and Utah never again failed to elect senators. Another concern was that when deadlocks occurred, state legislatures were unable to conduct their other normal business; James Christian Ure, writing in the South Texas Law Review, notes that this did not in fact occur. In a deadlock situation, state legislatures would deal with the matter by holding "one vote at the beginning of the day—then the legislators would continue with their normal affairs". Eventually, legislative elections held in a state's Senate election years were perceived to have become so dominated by the business of picking senators that the state's choice for senator distracted the electorate from all other pertinent issues. Senator John H. Mitchell noted that the Senate became the "vital issue" in all legislative campaigns, with the policy stances and qualifications of state legislative candidates ignored by