Script: nodes {1, 2, 3*} where 2 and 3 are partitioned, and 3 is the current leader.
Node 2 fires its leader election timer, broadcasts RequestVotes to 1 and 3, only 1 gets it, but now 3 is ignored for the term of its leadership and 2 is the only node capable of quorum. In a decent implementation 3 will be nack'd the next time it sends an AppendEntries to 1, and 1 will pass along the current term. 3 isn't hearing from the leader so broadcasts RequestVotes (either failing once due to failure to hear the current term from 1, or jumping straight into the next term, which actually increases the ratio of cluster livelock). Leadership bounces back and forth rapidly, making your cluster worthless.
The current hotness is spec paxos, which gets the positive trade-offs of both cheap paxos and fast paxos, if you're able to actually implement it in your DC (has networking assumptions).