Nye. The 1940 Senate election was another very dramatic one. Langer defeated incumbent Lynn Frazier in the Republican primary, and then faced both the Democratic candidate, Charles Joseph Vogel, and Republican/NPL Congressman William Lemke, who declined to run for reelection to Congress in order to run for the Senate as an independent. Langer won the election with 38% of the vote. Because of the trials mentioned above, Langer's qualifications were questioned under Article 1, Section 5 of the Constitution, which declares the U.S. Senate the ultimate judge of its members' elections, qualifications, and returns. The Senate seated Langer conditionally and began an investigation into his trials. The Committee on Privileges and Elections found Langer guilty of "moral turpitude" and unqualified to be a U.S. senator. The full Senate reversed the committee and voted to seat Langer. Biographer Glenn H. Smith calls Langer's Senate career "A Study in Isolationism, 1940–1959" and emphasizes his close ties with German American and Scandinavian American voters who bitterly remembered the First World War in the Dakotas and deeply distrusted Britain and the United Nations. Like Senator Henrik Shipstead of Minnesota, Langer championed non-interventionism and supported minimizing America's involvement in World War II. At home, he concentrated on making life easier for North Dakotan farmers by raising wheat prices and granting government relief. He was also adamant about implementing affordable healthcare for everyone. As a senator, he served on the Post Office, Civil Service and Indian Affairs committees. He and Shipstead were the only senators to vote against the United Nations Charter in 1945. He was also one of seven senators to oppose full U.S. entry into the United Nations. After African-American organizations asked Langer to propose a bill for the federal government to pay for the repatriation of African-Americans to the African continent, he did so. The bill, S. 1800, failed to pass. In September 1950, Langer filibustered to prevent the override of President Harry S. Truman's veto of the McCarran Internal Security Act for five hours before collapsing. In 1951, Langer lobbied John J. McCloy, the U.S. High Commissioner for Germany, to grant a reprieve to Martin Sandberger, a high-ranking SS official who had been convicted of crimes against humanity and war crimes for his role in the mass murder of Jews and others in Estonia during the Holocaust. Although sentenced to die by the tribunal of the Einsatzgruppen trial, in no small part