Special election conducted after Republican Senator Frank Day was elected Lieutenant Governor by the state Senate on January 25, 1895. Day ran for the 2nd Congressional District seat in the general election causing Dunn to get his name on the ballot on the grounds that Day could not hold his seat whilst running for congress. Day lost his U.S. House bid to Republican U.S. Representative James McCleary. Both Day and senator-elect Dunn claimed the SD 06 seat, but Dunn won the election contest and was sworn in on January 26, 1897.