and Hawaii, admitted to statehood in 1959, have never chosen a U.S. senator legislatively. The first election subject to the Seventeenth Amendment was a late election in Georgia held June 15, 1913. Augustus Octavius Bacon was however unopposed. The first direct elections to the Senate following the Seventeenth Amendment being adopted were: In Maryland on November 4, 1913: a class 1 special election due to a vacancy, for a term ending in 1917. In Alabama on May 11, 1914: a class 3 special election due to a vacancy, for a term ending in 1915. Nationwide in 1914: All 32 class 3 senators, term 1915–1921 Nationwide in 1916: All 32 class 1 senators, term 1917–1923 Nationwide in 1918: All 32 class 2 senators, term 1919–1925 Court cases and interpretation controversies In Trinsey v. Pennsylvania (1991), the United States Court of Appeals for the Third Circuit was faced with a situation where, following the death of Senator John Heinz of Pennsylvania, Governor Bob Casey had provided for a replacement and for a special election that did not include a primary. A voter and prospective candidate, John S. Trinsey Jr., argued that the lack of a primary violated the Seventeenth Amendment and his right to vote under the Fourteenth Amendment. The Third Circuit rejected these arguments, ruling that the Seventeenth Amendment does not require primaries. Another subject of analysis is whether statutes restricting the authority of governors to appoint temporary replacements are constitutional. Vikram Amar, writing in the Hastings Constitutional Law Quarterly, claims Wyoming's requirement that its governor fill a senatorial vacancy by nominating a person of the same party as the person who vacated that seat violates the Seventeenth Amendment. This is based on the text of the Seventeenth Amendment, which states that "the legislature of any state may empower the executive thereof to make temporary appointments". The amendment only empowers the legislature to delegate the authority to the governor and, once that authority has been delegated, does not permit the legislature to intervene. The authority is to decide whether the governor shall have the power to appoint temporary senators, not whom the governor may appoint. Sanford Levinson, in his rebuttal to Amar, argues that rather than engaging in a textual interpretation, those examining the meaning of constitutional provisions should interpret them in the fashion that provides the most benefit, and that legislatures' being able to restrict gubernatorial appointment authority provides a