California Representative Sala Burton came to the House via the "widow’s mandate" when her husband, Phillip Burton, died unexpectedly while in office. Upon announcing her intention to run in the special election for his seat, she vowed to follow in his footsteps and represent “the hungry, the poor, the children, the aged—those people who don’t have a lot of lobbying being done for them.” Burton served in Congress for four years, until her death in 1987.