He was an unsuccessful candidate for reelection in 1932 to the Seventy-third Congress, and for election in 1934 to the Seventy-fourth Congress and in 1936 to the Seventy-fifth Congress.
He was unable to win a second term in 1932 to serve in the Seventy-third Congress, and also failed to secure election to the Seventy-fourth Congress in 1934 and the Seventy-fifth Congress in 1936.