On March 25, California held a special election for State Senate, 23rd district. The Libertarian, Jeff Hewitt, a city councilman, placed fourth in a five-person race, polling 6.5%. This is the 86th election for federal or state office in which a minor party member has run in a top-two system, and in which there were at least two major party members running. In all 86 instances, the minor party member did not place first or second. Here is a link to the election returns.