Even after Nikki Haley dropped out of the Republican presidential primary, effectively handing the party’s nomination to former President Donald J. Trump, nearly 20 percent of G.O.P. primary voters have cast ballots for someone other than Mr. Trump. The Pennsylvania primary on Tuesday, where Ms. Haley won more than 16 percent, was just the latest example.

These anti-Trump votes have been closely watched, particularly in light of the unusually high number of votes for “uncommitted” and candidates other than President Biden in this year’s Democratic primary.

Ballots cast for candidates who have suspended their campaigns are sometimes called zombie votes. This phenomenon is hardly new.

In fact, a review of contested primaries since 2000 reveals that sizable shares of the electorate routinely chose someone other than the eventual nominee, even after all other serious contenders had dropped out.

In 2020, Senator Bernie Sanders of Vermont withdrew from the Democratic primary on April 8, leaving Joseph R. Biden Jr. as the only serious candidate in the race. Still, in the weeks and months that followed, Mr. Sanders received votes. In the Pennsylvania Democratic primary on June 2, 2020, for example, more than 20 percent of voters chose someone other than Mr. Biden, including 18 percent who selected Mr. Sanders.

The zombie vote in this year’s Republican primary has actually been low by historical standards. In Democratic and Republican primaries going back to 2000, roughly a quarter of voters picked a candidate other than the eventual nominee even after all the other serious contenders had exited the race.

There are many factors that lead to zombie votes. Not all of them indicate a true protest vote from party loyalists against the eventual nominee.

One factor is the rise of early voting and mail ballots. In Florida, for example, around one in three Republican voters had mailed their ballots before Ms. Haley dropped out on March 6.

However, she has continued winning a decent chunk of votes in states where nearly all voting has occurred after her departure. In the Wisconsin election on April 2, Ms. Haley won 13 percent of the vote.

The Trump campaign has argued that some of Ms. Haley’s support has come from Democrats voting in Republican contests. This may explain the zombie vote in, for example, Georgia, where any voter can vote in either presidential primary.

But the pattern has persisted even in states like Pennsylvania, Connecticut and New York where the primaries were open only to registered Republicans.

Unlike protest votes against incumbent presidents in the form of minor candidates and ballots cast for “uncommitted,” contested primaries feature big-name candidates who get wide media exposure, have clear policy differences and forge emotional connections with many voters. Perhaps the affinity some voters develop is the easiest explanation of the persistent zombie vote across so many election cycles.

We shouldn’t expect the zombie vote to go away any time soon. In the past, the share of voters still supporting candidates who had already withdrawn remained relatively consistent, even on the last day of primaries held before the party conventions. And there is no pattern linking the size of the zombie vote to the eventual nominee’s chances of winning or losing in the general election.

For Mr. Trump, what matters is how many of Ms. Haley’s primary voters will rally behind him come November. Polls have shown that her supporters are likely to say they will vote for Mr. Biden. Even so, those same polls often find that many of those voters already supported Mr. Biden in 2020.

Ohio Democratic Sen. Sherrod Brown faced immediate backlash Tuesday after video circulated of him refusing to answer a question about whether he supports the Biden administration’s push to “ban” gas-powered cars.

“Senator Brown, do you think that gas cars should be banned,” Brown was asked while walking down the street in Washington, D.C. in a video posted online. 

After Brown didn’t answer and kept walking, he was asked if he “supports the EPA’s decision to ban gas cars?”

Brown again declined to answer before he was asked a third time a “yes or no” question asking, “Should gas cars be banned?”

VULNERABLE DEM SENATOR BLASTED OVER VOTING RECORD AFTER AD TOUTS STRENGTH ON IMMIGRATION: ‘WON’T BE FOOLED’

Brown declined to answer a third time and continued on his way.

“While facing his toughest election yet, Sherrod Brown is running from his decades-long record of supporting green energy schemes that burden hardworking Ohioans with higher prices and cripple our energy sector,” Reagan McCarthy, communications director for Brown’s Senate opponent, Republican businessman Bernie Moreno, told Fox News Digital in a statement. 

“Make no mistake, Brown supported Joe Biden’s radical anti-energy agenda since day one of this administration.”

Moreno also posted the exchange on X, saying, “Sherrod Brown won’t answer because the truth is that he is a green new deal radical that wants to crush American autoworkers and hand our industry to China.”

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“Sherrod Brown and Joe Biden don’t just want to ban gas cars, they want to overhaul the entire American economy to appease their far-left base,” National Republican Senatorial Committee Spokesman Philip Letsou told Fox News Digital. 

“The Democrats’ green energy agenda is enriching China while wreaking havoc on American manufacturers, and Sherrod Brown is with them every step of the way.” 

The exchange also generated criticism from social media users.

“That’s because Sherrod Brown is a Green New Deal radical who agrees with Biden!!!” Donald Trump Jr. posted on X.

Sen. Sherrod Brown, D-Ohio, during senate votes in the U.S. Capitol Jan. 23, 2024. (Tom Williams/CQ-Roll Call, Inc via Getty Images)

Some on social media pointed to the fact that Brown has voted against Biden’s emissions agenda in the past and has pushed back against Biden’s EPA. 

“This is bizarre,” American Commitment President Phil Kerpen posted on X. “He actually voted right! To stop Biden’s EPA gas car ban! I mean, we knew he’d snap back after the election. But he can’t even bring himself to play the part???”

Brown has voted with President Biden nearly 100% of the time and voted to confirm 99% of Biden’s nominees. 

MAGA-ENDORSED BERNIE MORENO SET TO SQUARE OFF AGAINST INCUMBENT SHERROD BROWN IN CRITICAL OHIO SENATE RACE

A Brown spokesperson told Fox News Digital “Sen. Brown doesn’t tell anyone what kind of car they should drive.

“He just wants more cars made in Ohio by autoworkers making middle-class wages. That’s why he has stood up to the administration when their policies were wrong for Ohio’s auto industry, and why he’s fighting to ban Chinese electric vehicles.”

The Biden administration recently finalized a slate of highly anticipated environmental regulations curbing gas-powered vehicle tailpipe emissions as part of its broader efforts to reduce greenhouse gas emissions and combat global warming.

Under the new plan, automakers will be forced to rapidly curb the emissions of greenhouse gases, hydrocarbons, nitrogen oxides and particulate matter from new passenger cars, light trucks and larger pickups and vans beginning with model year 2027 vehicles. 

Placard on the exterior of the EPA Building in Washington, D.C. (iStock)

“At a time when millions of Americans are struggling with high costs and inflation, the Biden administration has finalized a regulation that will unequivocally eliminate most new gas cars and traditional hybrids from the U.S. market in less than a decade,” American Fuel & Petrochemical Manufacturers President and CEO Chet Thompson and American Petroleum Institute President and CEO Mike Sommers said in a statement after the EPA rules were announced.

“As much as the president and EPA claim to have ‘eased’ their approach, nothing could be further from the truth.”

Brown is facing a hotly contested re-election contest against Moreno in November that the Cook Political Report ranks as a toss-up and many believe provides one of the best chances Republicans have to gain control of the Senate in a state Trump carried by eight points in 2020. 

Fox News Digital’s Thomas Catenacci contributed to this report

Get the latest updates from the 2024 campaign trail, exclusive interviews and more at our Fox News Digital election hub

The Supreme Court justices voiced doubt Wednesday about a strict Idaho law that would make it a crime for doctors to perform an abortion even for a woman who arrives at a hospital suffering from a serious, but not life-threatening, medical emergency.

Solicitor Gen. Elizabeth B. Prelogar, representing the Biden administration, said such cases are rare and tragic. They are not elective abortions, she said, but pregnancies that have turned into medical emergencies.

Prelogar urged the high court to rule that federal emergency care law applies nationwide and sometimes requires hospitals and their doctors to perform an abortion — regardless of any state restrictions on the procedure — if a pregnant patient’s health or life is at risk.

The justices sounded closely split, but Prelogar’s argument appeared to gain traction with some conservatives.

The clash over emergency rooms is the first direct challenge to a state’s abortion law to come before the high court since the justices overturned Roe vs. Wade in a 5-4 vote in 2022.

The court’s conservatives said then that states and their lawmakers were free to restrict or regulate abortion.

Idaho’s lawmakers voted to forbid abortion except when it is “necessary” to prevent the patient’s death. In court, their lawyers argued that the authority to regulate doctors and the practice of medicine rests with the state.

But the Biden administration sued Idaho and said it was violating the federal Emergency Medical Treatment and Labor Act that Congress adopted in 1986. The law requires hospitals receiving federal funds to provide “necessary stabilizing treatment” to patients who face a medical emergency.

“For some pregnant women suffering tragic emergency complications, the only care that can prevent grave harm to their health is termination of the pregnancy,” the administration’s attorney said. In such situations, delay is dangerous, Prelogar added.

Idaho’s attorney, Joshua Turner, ran into sharp questions from several conservatives.

Justice Amy Coney Barrett questioned whether Idaho would use its laws to prosecute doctors who perform emergency room abortions. Chief Justice John G. Roberts Jr. and Justice Brett M. Kavanaugh also voiced doubt about the state’s argument.

Barrett cast a key vote to strike down Roe vs. Wade, but took on the Idaho attorney Wednesday for refusing to say whether doctors could perform abortions in certain emergencies.

Justice Sonia Sotomayor cited real cases from Florida and elsewhere, but Turner refused to give a yes-or-no answer as to whether such abortions would be legal in Idaho.

“Counsel, I’m kind of shocked actually because I thought your own expert has said these kinds of case were covered,” Barrett said.

“It’s a subjective standard … and very case-by-case,” Turner replied.

The exchange highlighted the problem cited by emergency room doctors in Idaho. They cannot know for sure whether an abortion would be legal under the state’s law.

What happens if the state’s lawyers believe a doctor’s intervention was not justified? “Would they be prosecuted under Idaho’s law?” Barrett asked.

Even if other doctors support the decision, “what if the prosecutor thought differently?” she said.

Roberts pressed the same point. “What happens if a dispute arises with respect to whether or not the doctor was within the confines of the Idaho law or wasn’t? Is the doctor subjected to review by a medical authority?”

Possibly, according to the state attorney. “The Board of Medicine has licensing oversight over a doctor,” Turner replied.

Kavanaugh said he was uncertain what was at stake because the state had changed its view over what emergency conditions could justify an abortion.

Justice Elena Kagan said the law has resulted in six pregnant women being airlifted to neighboring states to obtain abortions.

Justices Sotomayor and Ketanji Brown Jackson were also sharply skeptical of Idaho’s argument.

Prelogar, the Biden administration’s attorney, assured the conservative justices that federal law includes “conscience protections” for doctors and hospitals morally opposed to abortion.

The case of Moyle vs. United States poses a clash between the federal law that requires hospitals to provide emergency care and the state’s authority to regulate doctors and the practice of medicine.

Regardless of how the court rules in the Idaho case, the outcome should have no direct effect in California or other states where abortion remains legal.

Abortion-rights supporters gather outside the Supreme Court building Wednesday.

(Andrew Harnik / Getty Images)

Turner said 22 states now prohibit most abortions, and the court’s ruling could apply to all of them.

But Prelogar said Idaho is among only six states that make no exceptions for protecting the health of a pregnant patient.

Doctors in Idaho contend the law endangers patients.

In medical emergencies, “delay puts the patient’s life and health at risk. But the lack of clarity in the law is creating fear in our physicians,” said Dr. Jim Souza, chief physician executive for St. Luke’s Health System in Boise.

He said doctors in emergency rooms often see pregnant women whose water has broken, or who have a severe infection or are bleeding badly. An abortion may be called for in such a situation, but doctors know they could be subject to criminal prosecution if they act too soon, he said.

“Doctors are leaving the state because of the fear surrounding this law,” Souza said in an interview.