Virginia Constitutional Amendment #1: Apportionment
There is a bizarre loophole in the Virginia Constitution regarding the reapportionment of U.S. House of Representatives, Virginia Senate, and Virginia House of Delegates districts (which occurs every 10 years following the Census). If a member of any of those legislative bodies leaves office (due to death, resignation, etc.) before his/her term is up but after reapportionment, their replacement can be (and in some cases has been) selected by special election from the newly redrawn district.