What's in a Primary?
The New Hampshire results are in, and Nikki Haley came up short, garnering 43% of the Republican vote in that state.

The New Hampshire results are in, and Nikki Haley came up short, garnering 43% of the Republican vote in that state. While commentators almost universally believed that the outcome is a foregone conclusion, Haley vowed to fight on and will next face Trump in her home state of South Carolina slated for February 24. Presumably, she knows the voters there, and they know her. She served six years as its governor before going to the UN as US Ambassador.
Trump claims he is way ahead in the polls in South Carolina. But, don't be too sure. Some polls had him 18 points ahead in New Hampshire, and he only eked out an 11-point win with a dismal showing among independent and college-educated voters.
While Churchill counseled magnanimity in victory, Trump was churlish, smearing Haley's clothing as cheap, mocking her for not using her real first name, Nimarata, and threatening that if she did much better in the primaries, there would be an immediate investigation.
This will be a quiet month for Haley. If she is to succeed, she must separate herself from Trump among uncertain GOP voters. This will be difficult as Trump has refused to debate her. She also will need big money. Billionaire investor Ken Langone, a Republican and a true patriot, promised her a big contribution if she made a decent showing in New Hampshire. We hope Ken and other mega-donors will be impressed that, while Trump won 74% of the Republican vote to Haley's 25%, Haley won 60% of the independent vote to Trump's 38%. We've never seen a gap between the independent vote and the Republican vote in an NH GOP primary like we saw last night. Trump won R's by 49, Haley took independents by 22—a swing of 71 points. The previous high was 40.
Trump’s a quasi-incumbent, and Haley did as well in NH as challengers to incumbents or quasi-incumbents like Kennedy in 1980, Buchanan in 1992, and Bradley in 2000. None of those challengers ended up as the nominee. But the incumbents they challenged all lost in November.
It may not be so barren a month for the never-Trumpers. Any day now, the DC Circuit is due to render its decision on Trump's appeal from Judge Chutkan's rejection of his immunity defense in the January 6 criminal trial. The Supreme Court will hear oral argument in the Colorado XIV:3 disqualification case on February 9, and we may get an indication of where that is going.
If Trump is convicted by a jury in DC, it should be a brand-new ballgame for the GOP and the country.
📰 In the News
Trump and Giuliani Can’t Easily Wiggle Out of Defamation Payments
As any creditor will tell you, there is a difference between presenting a bill and getting it paid. As any creditor’s lawyer will say to you, there is a difference between getting a judgment and getting it satisfied. And, in case you were wondering, there is often a slip between the cup and the lip.
Two election workers obtained a defamation judgment in Washington for $146 million against Donald Trump’s lawyer and ally, Rudy Giuliani—a judgment that Giuliani says he can’t possibly satisfy. Judge Beryl Howell of the U.S. District Court for the District of Columbia ordered Giuliani to compensate the workers immediately, expressing concern that the former New York City mayor may have been dishonest about his finances and might not comply with the judgment. The award sent Giuliani to seek refuge of the bankruptcy court, alleging in sworn documents that he had between $100 million and $500 million in liabilities and $1 million to $10 million in assets. The bankruptcy filing may allow the 79-year-old to appeal the judgment without posting a bond, but the bankruptcy doesn’t mean that Giuliani will get off scot-free. The bankruptcy may avail him little. Defamation is an intentional tort that is not dischargeable in bankruptcy. The unsatisfied portion of the judgment will follow him eternally.
See my full piece in the Washington Monthly for whether the defamation judgments against Trump and Giuliani are collectible.
With Trump’s victory in Iowa, we’re inching toward autocracy
Iowans voted this week in the Republican primary race, which shouldn’t mean very much. Iowa’s population is 3.2 million, about 1 percent of the total United States. There are 2,083,000 registered voters there, with 718,000 registered Republican. Only 110,298 voted in the caucus, and 56,260 voted for former President Trump — about 2.7 percent of Iowa’s registered voters.
But Iowa represents a tremendous psychological victory for Trump. Not a ho-hum, but a harbinger of things to come.
Mainers like to brag that “as Maine goes, so goes the nation,” but Iowa hardly enjoys the same bellwether status. Winners of the GOP Iowa caucuses have included Ted Cruz, Rick Santorum and Mike Huckabee, whose candidacies went nowhere. Yet there is the bandwagon effect leading people I respect to tell us not to be in denial, predicting that Trump will be the Republican nominee.
So what does Iowa mean and what doesn't it? Continue reading in The Hill.
Trump the Autocrat at the Counsel Table
This past week, Donald Trump, the autocrat-as-defendant, was in court, going so far as to contribute to a closing statement, which is about as rare as a passenger walking up to the cockpit and taking control. The move smacked of the way his mentor, the crooked lawyer Roy Cohn, won an acquittal a half-century ago.
Trump claims the cases against him constitute “election interference” by Joe Biden to derail his campaign. Now, Trump says he will attend all trials and hearings, even when he is not required to be there.
Norm-breaking isn’t exactly new for Trump, who, as president, smashed them daily, attacking the free press as “enemies of the people,” immigrants, Muslims, military heroes, and cherished allies. He tried to steal an election, after all, and this time around, he vows to be dictator for a day and terminate the Constitution.
Still, nothing Trump has said or done compares with his assertion that a president has a right to assassinate his political enemies with immunity so long as he’d been acquitted in an impeachment trial. Read on in the Washington Monthly.
🎙 On Conversations
Tom Graham, a Russia expert and author of the terrific new book Getting Russia Right was one of three former national security officials to meet with Russian Foreign Minister Sergey Lavrov in secret back channel talks last April, possibly paving a way forward to end the war in Ukraine. He tells me why our post-Soviet effort to partner with Russia failed in this episode of Conversations with Jim Zirin, airing today on CUNY TV at 10:30 pm ET.
🎧 On the go and prefer to listen to the show? Subscribe to Conversations on Apple Podcasts, Spotify, or wherever you get your podcasts and never miss a new episode.
📝 Consider leaving a review for the show on Apple Podcasts. Your support is greatly appreciated and I love hearing from my listeners!
👋 The Last Word
“In War, Resolution; In Defeat, Defiance; In Victory, Magnanimity; and in Peace, Good Will.”
—Winston Churchill
If you find the content interesting, please share with your friends. Our aim is to enlighten. And if a friend forwarded you this newsletter, subscribe below to receive Beyond the Headlines directly. Thanks for reading, see you all in two weeks!
📱 Follow me on: X | Facebook | Instagram | Threads | YouTube | Apple | Spotify