Recall is a procedure that allows citizens to remove and replace a public official before the end of a term of office. Recall differs from another method for removing officials from office – impeachment – in that it is a political device while impeachment is a legal process. Impeachment requires the House to bring specific charges and the Senate to act as a jury. In most of the recall states, specific grounds are not required, and the recall of a state official is by an election. Eighteen states permit the recall of state officials. A recent, high-profile example of the recall process was the recall of California Governor Gray Davis and his replacement with Arnold Schwarzenegger in 2003.