Several western states — Arizona, Oregon, Idaho, Nevada and California — provide some provision for recalling state officials. But Hall said few recall elections are considered successful.

A detailed study of the issue by the National Council of State Legislators showed that only a few of the 107 recall elections in the United States have been successful.

Two state officials were recalled in the early 1900s, one for being "an alcoholic and a criminal." Two senators were recalled in 1983, and Oregon voters recalled a legislator in 1988. Two governors — in California and in North Dakota — have been recalled.

Commissioners also questioned how to sync Hogue's resolution with impeachment, which judges are subject to.

"In terms of scope, there are a lot of questions one would have," Howe said.

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