the death of Robert Byrd. As there was more than one year remaining on Manchin's term as governor, a special election was held, which Tomblin won. He became governor on November 13, 2011 to complete the term. Disputes over powers of acting governors The powers of an acting governor came into dispute during the 1980 Democratic primary presidential campaign of Jerry Brown, then governor of California. When he was campaigning out of state, which was often in late 1979 and early 1980, Mike Curb, a Republican who was then serving as lieutenant governor of California often used his position as acting governor to veto legislation, promulgate executive orders, issue proclamations, appoint Republican appellate court justices, and to do other things that Brown would not likely have done had he been present in the state. This eventually resulted in litigation, much of which went in Curb's favor. Powers of an acting governor had previously been questioned in the mid-1970s in Kentucky. In her capacity as acting governor of Kentucky in Julian Carroll's absence, Thelma Stovall, then-lieutenant governor, acting as governor, issued pardons, called the Kentucky General Assembly into special session to enact legislation limiting property tax increases, and purported to veto the legislature's repeal of its ratification of the Equal Rights Amendment. The authority of the lieutenant governor of Kentucky to act as governor when the elected governor is out of state was repealed under a 1992 amendment to the Kentucky Constitution. In 1993, in Pennsylvania, Governor Robert P. Casey underwent surgery that left him incapacitated for months, thus leaving Lieutenant Governor Mark Singel as acting governor. During that time, Singel fulfilled all duties of the office of governor. Following the death of New Hampshire Governor Hugh Gallen, Vesta M. Roy, as president of the state Senate, served as acting governor of New Hampshire from December 30, 1982, to January 6, 1983. Practices in this area are anything but uniform from state to state. In Rhode Island, for example, the lieutenant governor never acts as governor, even if the governor has left the state. In most of the states, when the governor dies, resigns or is removed from office (via impeachment conviction), the next in line become the new governor, succeeding to the office and powers. See also Acting President of the United States Acting (law) References Government occupations Gubernatorial titles