Is President Joe Biden the first person to win a presidential primary as a write-in candidate? No, that's not true: Several people have won presidential primaries as write-in candidates, with such victories dating back to at least the early 20th century. Others won the New Hampshire presidential primary specifically as write-in candidates long before Biden.
The claim appeared in a post (archived here) published on January 23, 2024, on X, formerly known as Twitter. The post read:
NEW: Joe Biden becomes the first person to ever win a presidential primary as a write-in candidate.
This is how the post appeared on X at the time of writing:
(Source: X screenshot taken on Thu Jan 25 20:23:56 2024 UTC)
Biden won the New Hampshire Democratic presidential primary as a write-in candidate on January 23, 2024 (archived here). The win followed a write-in campaign led by Biden supporters in New Hampshire that began after it was announced that Biden would not be on the New Hampshire presidential primary ballot (archived here). By state law, New Hampshire holds the first presidential primary in the country (archived here) and it bucked the Democratic National Committee's plans to make South Carolina the first presidential primary state of the 2024 presidential race (archived here). Because of New Hampshire's decision, Biden decided not to enter his name onto the New Hampshire Democratic presidential primary ballot (archived here).
However, Biden is not the first person to win a presidential primary via write-in votes.
Eric Ostermeier, a research fellow at the University of Minnesota's Humphrey School of Public Affairs, and founder of the nonpartisan political news website Smart Politics, told Lead Stories in a January 25, 2024, email that the history of write-in candidates' presidential primary victories "date back to early contests more than 100 years ago." Ostermeier pointed to several examples throughout the years, including former President Theodore Roosevelt's 1916 win in the New Jersey Republican presidential primary as a write-in candidate, and the write-in win of the eventual Republican nominee that year, Charles Hughes, in the Vermont presidential primary. In 1928, former President Herbert Hoover won the Massachusetts presidential primary as a Republican write-in candidate. In 1960, former President John F. Kennedy won presidential primaries as a Democratic write-in candidate in Massachusetts, Pennsylvania and Illinois.
For historical context, Ostermeier added:
Keep in mind, prior to 1972, very few delegates were awarded via primaries, so many eventual candidates whose names were put up for nomination at the national conventions did not compete in them - and, of those that did, some were often 'favorite sons' or stand-ins for more nationally-known candidates.
The New Hampshire presidential primary also has a history of write-in candidate victories. Dante Scala, a professor of political science who specializes in presidential campaigns and politics at the University of New Hampshire, confirmed to Lead Stories in a January 25, 2024, email that former U.S. Ambassador to the United Nations Henry Cabot Lodge Jr. and former President Lyndon B. Johnson both won presidential primaries in New Hampshire as write-in candidates.
Lodge, who won the New Hampshire Republican presidential primary in 1964, was not even a presidential candidate at the time of his win (archived here). Johnson won the New Hampshire Democratic presidential primary in both 1964 and 1968 (archived here).
Lead Stories has also fact checked the claim that 50,000+ Democratic votes were "found" for President Joe Biden in the 2024 New Hampshire primary.
