Return to Sender: Bowman Joins Rare “Primary In, Primary Out” Class
June 29, 2024 · 1:24 PM EDT
New York Rep. Jamaal Bowman’s loss to George Latimer in the 16th District Democratic primary puts the progressive in rare company among House members.
While it is uncommon for any incumbent to lose a primary race — it happens just 2 percent of the time on average in any given cycle — it is exceedingly rare for a representative to lose a primary challenge after defeating another incumbent in a previous primary election. And it’s even more rare for those primary wins and losses to be a function of ideological differences rather than corruption or misconduct, as Bowman’s were and as Virginia Republican Bob Good’s likely loss this year is as well.
Bowman, who lost to the more establishment-friendly Latimer by 17 points, had ousted party stalwart Eliot Engel in the 2020 Democratic primary. Engel can now welcome his one-time opponent into the small “primary-in, primary-out” club: he got to the House in 1988 by beating the legendary Mario Biaggi following Biaggi’s corruption indictment.
Corruption is a recurring theme among this group of members. Of the 12 cases similar to Bowman’s over the past 50 years, 9 of them involve corruption investigations or accusations of misconduct in some capacity. Most of the others involve significant generational contrasts.
An additional four members — Illinois’ Marie Newman, Michigan’s Hansen Clarke, New Jersey’s Neil Gallagher, and New York’s James Scheuer — beat incumbent members of Congress in primaries only to see their districts redrawn and later lost to fellow incumbents in primary elections.
Michigan’s Carolyn Cheeks Kilpatrick beat Rep. Barbara-Rose Collins in 1996 as the congresswoman faced an ethics investigation into misuse of campaign and official funds. But Kilpatrick lost to Clarke in 2010 under the cloud of a corruption scandal that sent her son, Detroit Mayor Kwame Kilpatrick, to prison.
Pennsylvania’s Chaka Fattah beat Lucien Blackwell in 1994 but was later indicted on corruption charges and lost the 2016 Democratic primary to Dwight Evans.
Back in 1978, Oklahoma Democrat Mike Synar won a primary challenge against Rep. Ted Risenhoover, who he portrayed as a playboy, informing voters Risenhoover slept on a “heart-shaped waterbed” in the nation’s capital. But Synar’s luck ran out in 1994, when he lost narrowly to a conservative Democratic primary challenger named Virgil Cooper who spent little money on his race but was backed by the NRA and tobacco companies. Cooper lost the general election, narrowly, to future Sen. Tom Coburn.
Kentucky Democrat Carroll Hubbard defeated an incumbent Democrat in 1974 but lost his own primary in 1992 after becoming mixed up in the House banking scandal. The Democrat Hubbard beat in 1974, Frank Stubblefield, had himself defeated an incumbent Democrat, Noble Gregory, in 1958.
Another Democrat, New York’s Stephen Solarz, was also implicated in the 1992 banking scandal and lost his primary that year to Nydia Velazquez, who’s still in Congress today. Solarz himself got to Washington, DC by defeating a Democratic incumbent, Bertram Podell, in 1974. Podell was facing corruption charges at the time.
In 1978, Texas Democrat John Andrew Young lost renomination following accusations that he forced a staffer to have sex with him to keep her job. He had previously ousted incumbent John Junior Bell in the 1956 Democratic primary.
A rare Republican in the club, Californian Andrew Hinshaw was personally recruited by President Richard Nixon to beat arch-conservative John Schmitz in the 1972 GOP primary. But Hinshaw only served two terms before losing a primary in 1976 to Robert Badham. Hinshaw was under indictment for corruption at the time.
Another incumbent, Louisiana’s Otto Passman, also lost renomination that year after facing accusations of influence peddling (he was later acquitted of the charges). Passman had won his seat in Congress by ousting an incumbent in the 1946 Democratic primary.
Indiana’s Ray Madden also received the boot in his 1976 primary, losing a generational matchup to the much younger state Sen. Adam Benjamin (the Almanac of American Politics cites news reports that Madden was “as senile as the day is long”). His exit came 34 years after he upset fellow Democrat William Schulte in a primary.
California Democrat Pete Stark is a provisional member of the club and also was on the losing end of a generational battle. He ousted longtime Rep. George Miller in 1972, and while he ultimately lost in the 2012 general election, not primary, it was against a fellow Democrat, now-Rep. Eric Swalwell. Swalwell used some of the same arguments Stark had levied against Miller 50 years earlier in that campaign.
Bowman (and Good, whose race remains uncalled but does not look promising for the incumbent) are outliers in their situations, two members who won and lost ideological primaries to bookend their congressional careers.
But they may also be the start of a trend. Missouri’s Cori Bush, who defeated Rep. Lacy Clay in the 2020 Democratic primary, faces a well-funded challenge from St. Louis County Prosecutor Wesley Bell on Aug. 6.
Bell is running as a more establishment-friendly alternative to the incumbent's strident progressivism. But as was the case with so many other members foiled by primaries in years past, Bush is also under investigation for misuse of funds.
Updated 7/1/24: Stephen Palazzo defeated Gene Taylor in the 2010 general election, not primary. He defeated Taylor in the 2014 GOP primary.