Similarly, New Hampshire has no lieutenant governor, but the state senate elects a president who is the "de facto" lieutenant governor, given that in the event of the governor's death, resignation, or inability to serve, the president of the senate acts as governor until the vacancy is filled. New Jersey previously used the same system, but with the important proviso that the Senate president continued to serve in that position while also serving as acting governor. After Christine Todd Whitman resigned as governor, Donald DiFrancesco spent nearly a year as acting governor. As a result of his tenure, questions were raised about the propriety of such a system, particularly with regard to separation of powers–related issues. A constitutional amendment was enacted in 2005 to create the office of lieutenant governor effective at the 2009 election.