 With the Judicious Use of Surveillance Tools in Counterterrorism Efforts (JUSTICE) Act of 2009 (H.R.4005), Holt increased limits on governmental power with respect to counterterrorism efforts.On June 6, 2013, Holt became the first Democrat to become a candidate in the special election to fill the U.S. Senate seat vacated by the death of Frank Lautenberg.