He was subsequently voted out of office, becoming the second governor in the history of the United States to be recalled after Lynn Frazier of North Dakota in 1921. He was replaced by Republican Arnold Schwarzenegger. The Lieutenant Governor of California is separately elected during the same election, not jointly as the running mate of the gubernatorial candidate. California has had a governor and a lieutenant governor of different parties 26 of the past 31 years. This occasionally becomes significant, since the California Constitution provides that all the powers of the governor fall to the lieutenant governor whenever the governor is not in the state of California, with the lieutenant governor sometimes signing or vetoing legislation, or making political appointments, whenever the governor leaves the state. In practice, there is a gentlemen's agreement for the lieutenant governor not to perform more than perfunctory duties while the governor is away from the state. This agreement was violated when Mike Curb was in office, as he signed several executive orders at odds with the Brown administration when Brown was out of the state. Court rulings have upheld the lieutenant governor's right to perform the duties and assume all of the prerogatives of governor while the governor is out of the state. The lieutenant governor is also the president of the California State Senate.