Quinlan became embroiled in a controversy regarding provision of state aid to private schools, which he and fellow Catholic MLAs Thomas Molloy and Alfred Canning supported.
The Catholic Vicar General, Father Anselm Bourke, established the Education Defence League with their assistance.
However, the issue became a major one in the 1894 election amongst the voting public, and all three MLAs lost their seats, Quinlan losing to former Fremantle mayor Barrington Wood.
Leake, a former opposition leader, was able to form government, and became the third Premier of Western Australia.
It was later held by Thomas Davy, Attorney General in the second Mitchell government, who was widely considered to be leadership material until his early death in 1933 (while playing cards at the Savoy Hotel).