Murphy ran for a second term in 2004 again against Ron Roberts. His re-election campaign saw controversy with a last minute write-in candidate, Donna Frye, a member of the San Diego City Council. A number of voters did not follow the proper procedure for supporting a write-in candidate, either misspelling the name of Donna Frye (usually as "Donna Fry") or writing her name in the blank but neglecting to fill in the corresponding bubble to indicate their preference. After a legal imbroglio involving three (unsuccessful) lawsuits, these votes were ultimately not counted, resulting in Murphy winning the official tally by approximately 2,000 votes.