party. This law was passed in 1963 by Democrats in the California state legislature to deal with a problem that had plagued the party for years. The previous law did not require a run-off at all, and whichever candidate in a special election who received a simple plurality of the vote won. Because Republicans tended to be more unified than Democrats, this law benefited Republicans—who would often run only one candidate who would win in a crowded field of candidates, even in strong Democratic districts. The idea behind changing the law was to require a run-off so that, under such a scenario, the top Republican who came in first would then have to face the top Democrat. However, in districts as overwhelmingly partisan as the districts of the East Bay, this meant that the candidate of the minority party had typically come in third or fourth in the special primary election, increasing the importance of the primary, and leading to possible upsets, like Harris unexpectedly losing to Green Party candidate Audie Bock, who had received less than 9% of the vote in the previous special election. Some people argued that this scenario as played out in these elections did not give voters a fair choice because a run-off should be held between the top two finishers, not the top finisher of each party. While Aroner, theoretically, could have challenged Perata two years later in the regularly scheduled election, political reality dictates that it is virtually impossible to defeat an incumbent legislator in a safe district. In California Democratic Party v. Jones, the Supreme Court of the United States struck down the blanket primary. California's partisan primary system was changed in 2010 by Proposition 14 and replaced with a jungle primary in which the top two finishers advance to a runoff without regard for partisan affiliation. The new jungle primary was first used in 2012. References Political terminology of the United States 1998 in California 1999 in California