In 1940, both he and sitting Governor Earl Kemp Long lost to Sam Houston Jones of Lake Charles in the pivotal Democratic primary. Charles E. McKenzie, who later went on to serve as a Representative in Louisiana's 5th Congressional District was named as the campaign manager for Noe. Noe and Earl Long later buried their differences. A Noe confidant, state Senator Joe T. Cawthorn of Mansfield, switched to the Long faction and undercut the Jones administration through his position as chairman of the Senate Finance Committee.