Fact Check

Biden the 1st Presidential Candidate to Win a Primary with Write-In Votes?

Biden left his name off of New Hampshire's 2024 ballot so South Carolina voters could be the first to officially pick him.

Published Jan 24, 2024

 (Joe Raedle / Getty Images)
Image Via Joe Raedle / Getty Images
Claim:
U.S. President Joe Biden is the only presidential candidate to win a primary election as a write-in candidate.

In a tradition literally enshrined in state law, New Hampshire voters trekked to the polls on Jan. 23, 2024, to cast ballots in the nation's earliest presidential primary election. Yes, Iowa's caucuses happen earlier, but the state law in question doesn't care about caucuses, only primaries. For the Democratic National Committee (DNC) and Democratic U.S. President Joe Biden's 2024 campaign, New Hampshire and Iowa just weren't the best places to start. They preferred South Carolina instead, where Biden won his first primary victory in 2020.

But the law is the law, and New Hampshire's vote still came first in the country. The Biden campaign held fast to its South Carolina strategy: The New Hampshire Democratic primary would proceed, but without Biden's name on the ballot. That way, New Hampshire voters could still vote for Biden via write-in, but officially, South Carolina would be the first to list him on the ballot. In the wake of the decision, New Hampshire Democrats began a campaign to ensure that people knew how to vote for the president.

As the results came in and it became clear that Democrats had written in Biden's name, the race was called, and supporters proclaimed on social media that Biden's New Hampshire victory made him the first presidential candidate to win a primary using only write-in ballots.

(X [formerly Twitter] user @stridinstrider)

While Biden did indeed win the primary just using write-ins, he's not the only presidential candidate to do so. In order to explain, we must go back to one of the most chaotic elections in American history, 1968.

A bit of context: In 1963, Lyndon B. Johnson became the 36th president of the United States after John F. Kennedy (JFK) was assassinated. Johnson easily defeated Republican challenger Barry Goldwater in the 1964 election, and under the 22nd Amendment, was eligible to run in 1968 because he had served less than two years of Kennedy's term. In his 1964 campaign, Johnson faced heavy pressure to choose JFK's popular younger brother Robert F. Kennedy (RFK) as his vice president. There was one problem: LBJ and RFK hated each other. Johnson chose Hubert Humphrey instead.

In the meantime, Johnson began sending troops to Vietnam. To massively oversimplify, this turned out to be a very bad move. As the United States became more and more involved in Vietnam War, Johnson became less and less popular. In late 1967, Johnson's 1968 reelection campaign gained its first Democratic challenger, Minnesota U.S. Sen. Eugene McCarthy, who ran on a strictly anti-war platform. On Jan. 31, 1968, the Tet Offensive, a massive guerilla attack launched by the Viet Cong that targeted and destroyed key command centers in the cities across South Vietnam, took the American public by surprise. Johnson's already low approval rating dropped even lower.

Which brings us to March 12, 1968, and the New Hampshire Democratic primary, the first in the nation then as now. Because Johnson was running for reelection, his campaign figured that simply being the sitting president would be enough for Johnson to easily secure the Democratic nomination. So, the campaign never filed to be included on New Hampshire's ballot, meaning voters would have to write Johnson in.

As the results poured in, it became clear just how unpopular he had become. McCarthy garnered over 40% of the primary vote and Johnson had under 50%. It was enough to convince RFK to launch his own presidential campaign. Realizing that his days in office were numbered, Johnson publicly announced on March 31, 1968, that he would not seek reelection. The rest of the 1968 presidential campaign was no less bizarre, for the record.

But in summary, since Johnson was never officially included on the New Hampshire Democratic primary ballot, his victory came from write-in votes, meaning that Biden is not the first presidential candidate to win a primary only using write-in votes.

This was not the only claim we checked about the 2024 New Hampshire primaries: On the Republican side, we also investigated whether Trump became the first candidate to win a primary in the state three times.

Sources

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Glass, Andrew. “McCarthy Nearly Upsets LBJ in New Hampshire Primary: March 12, 1968.” POLITICO, 12 Mar. 2016, https://www.politico.com/story/2016/03/mccarthy-nearly-upsets-lbj-in-new-hampshire-primary-march-12-1968-220521.
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Jack Izzo is a Chicago-based journalist and two-time "Jeopardy!" alumnus.