The victory of Republican Brian Bilbray in a special election to fill an empty House seat representing San Diego was by no means inevitable.

The victory of Republican Brian Bilbray in a special election to fill an empty House seat representing San Diego was by no means inevitable. The seat was left vacant following the Duke Cunningham bribery scandal; Bilbray is a former congressman who became a lobbyist (not a popular way to make a living); Democratic nominee Francine Busby ran an energetic and well-funded campaign; and national polls continue to suggest that Democrats will fare well this fall. Yet Busby attracted only 45 percent of the vote--not much better than John Kerry did in 2004, when he carried 44 percent of the district. Republicans would be wrong, however, to assume that they can rest easy: Bilbray prevailed in large measure because the national GOP pumped $4.5 million into his campaign, which it will surely not be able to do for every candidate. But these candidates can make one useful observation about the win: Bilbray campaigned on the need for strong immigration enforcement; his opponent committed a fatal gaffe by telling a group of Hispanics, "You don't need papers for voting." The majority registered its preference.