 In 1972 the party considered suing county clerks in Placer and Butte counties for refusing to allow voters to register as Libertarians.In 1978 Ed Clark, who had been the affiliate's chairman from 1973 to 1974 and later the national presidential candidate in 1980, ran as an independent for governor of California to gain party recognition and received over five percent.However, the Secretary of State ruled that the two percent requirement was for retaining party recognition and not gaining party recognition and that since Clark had ran as an independent and not a Libertarian it would not count either way.