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Can a Transaction with a Lower Gas Fee Still Be Included before a Higher-Fee Transaction?

Yes, in systems that rely on a first-price auction, a lower-fee transaction could theoretically be included first if the higher-fee transaction was submitted later and the block producer simply chose the earlier one. However, in MEV-driven systems, the block producer is economically incentivized to select the transaction that offers the highest total value (fee + MEV bribe).

In EIP-1559, the validator prioritizes based on the highest priority fee.

What Is EIP-1559 and How Did It Change the Gas Fee Mechanism on Ethereum?
How Does EIP-1559 Affect Gas Fee Predictability?
How Does the “Base Fee” and “Priority Fee” System Work under EIP-1559?
What Is EIP-1559 and How Did It Change the Gas Fee Mechanism?