The Clare by-election of 1828 was notable as this was the first time since the reformation that an openly Roman Catholic MP, Daniel O'Connell was elected. Clare was held by William Vesey Fitzgerald when he became the President of the Board of Trade. As this was seen to be an office of profit, Vesey-FitzGerald had to stand in a by-election. Daniel O'Connell decided to exploit a loophole in the Act of Union. It stated that Catholics could not sit in Westminster as a Member of Parliament (MP), but there was nothing about them standing for an election.