Stockwell Day continued to represent the same district in British Columbia to which he was elected in 2000 when he first entered the House of Commons as leader of the Canadian Alliance, even though he was a resident of Alberta at the time of his initial election. Conversely, Joe Clark was elected in a by-election in Nova Scotia on the very same date as Day, following his reelection to his second stint as leader of the Progressive Conservatives, but held that seat only until the 2000 election and then stood in the Alberta riding of Calgary Centre. In still other cases, a politician may run in a district other than the one they live in for personal reasons — such as having an established power base in that area from a prior political office, or simply not wanting to get drawn into a nomination contest with an existing incumbent. For instance, Jack Layton represented the electoral district of Toronto—Danforth for the entirety of his term as a member of the House of Commons, even though his personal residence was in the nearby district of Trinity—Spadina. Trinity—Spadina was concurrently represented by Layton's wife, Olivia Chow, and both districts corresponded to the areas that Chow and Layton had previously represented on Toronto City Council. However, a non-resident candidate may sometimes face accusations of being a parachute candidate, which may or may not compromise their ability to win the election depending on the circumstances. In recent federal elections, some non-resident candidates have won election while others have lost. A non-resident candidate who does win election is generally expected to establish a residence in or near the district soon afterward, although this is by public expectation rather than legal requirement. To be eligible for appointment to the Senate, a person must officially reside in the province which they are being appointed to represent. However, this criterion has historically been interpreted quite liberally, with virtually any form of property holding — including primary residences, second residences, summer homes, rental or retail holdings or even lots of undeveloped land — having been deemed to meet the requirement, as long as the senator listed it as their primary residence on paper regardless of whether they actually resided there in any meaningful way. Again, however, controversy may result among the general public around the definition of residency — for instance, Senator Pamela Wallin faced some controversy in 2008