After three previous attempts, Curtin was elected to the House of Representatives at the 1928 federal election, winning the Division of Fremantle. He is the only prime minister to represent a constituency in Western Australia. He remained loyal to the Labor government during the party split of 1931. He lost his seat in Labor's landslide defeat at the 1931 election, but won it back in 1934. The following year, Curtin was elected party leader in place of James Scullin, defeating Frank Forde by a single vote. The party gained seats at the 1937 and 1940 elections, with the latter resulting in a hung parliament. The ALP eventually formed a minority government in October 1941, when the Fadden Government lost a confidence motion.