On Jan. 23, 2024, New Hampshire residents played their traditional role as the first voters to cast their ballots in primary elections, a fact the state is so proud of, it's enshrined in state law. (In a legal loophole, the Iowa Caucuses, which do take place earlier, don't count because they're caucuses, not primaries).
As the results poured in and it became more and more clear that former U.S. President Donald Trump had the margins to win the vote, the election was called in his favor. Not long after, Fox News host Bret Baier said the following on air: "Donald Trump is now the only person ever to win the New Hampshire primary three times."
The clip was shared on social media by supporters of Trump's 2024 presidential campaign who celebrated the victory. Unfortunately, Fox News ought to have done a bit of fact-checking before allowing Baier to make that claim. While Trump has won the New Hampshire primary three times, he is not the only presidential candidate to accomplish the feat.
First, there is the case of the 22nd Amendment, which codified the two-term limit for presidential elections into the U.S. Constitution in 1951. The limit became tradition after George Washington refused to run for reelection in 1796, but it was not until after one president had served a third and fourth term that Congress decided to make it official. We figured that searching the electoral history of that President, Franklin D. Roosevelt, would have a good chance of being a counter-example. And indeed, searching through the newspaper archives from the New York Times revealed that Franklin D. Roosevelt won the Democratic primary in New Hampshire in all four of his elections: 1932, 1936, 1940 and 1944.
But this example may be unsatisfactory to some, since Roosevelt was a Democrat and you can reasonably make the case that Baier is specifically referring to the Republican primary. Unfortunately, even among Republicans, Trump still has company. In 1960, then-Vice President Richard Nixon won the New Hampshire primary in a landslide, but lost that year's general election to John F. Kennedy. Eight years later, Nixon won the both the 1968 New Hampshire Republican primary and the national election. And in Nixon's 1972 bid for re-election, he won the state's primary for a third time.
In conclusion, Trump's victory in New Hampshire did give him the rare distinction of winning a New Hampshire primary three times. However, he is not the first candidate, nor the first person to hold the office of President, Democrat or Republican, to accomplish the feat.
This is not the only claim we've seen made the 2024 New Hampshire primaries. We also examined whether Biden's victory meant he was the first ever candidate to win a primary election through only write-in ballots.