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Investigation of Tom Holman

Sep 22, 2025,

Overview

A corruption investigation involving former Trump administration official Tom Holman was shut down after evidence surfaced of him accepting $50,000 in cash in exchange for promising to steer contracts if Trump was re-elected. The discussion reviews the legal implications, jurisdictional barriers, prosecutorial discretion, statute of limitations, and the impact of political control over law enforcement.

Details of the Tom Holman Investigation

  • Tom Holman allegedly accepted $50,000 in a bag from undercover FBI agents posing as businessmen.
  • Holman promised to steer government contracts to these agents if Trump won re-election, implicating a quid pro quo arrangement.
  • The Justice Department and U.S. Attorney's Office in Texas initially launched a criminal investigation and recorded evidence.
  • The investigation was abruptly shut down after Trump was elected, preventing further evidence gathering or potential prosecution.

Legal Analysis of Bribery and Attempted Bribery

  • Taking cash and promising official action constitutes bribery or at minimum, attempted bribery, if the intended act doesn’t occur due to outside intervention.
  • The investigation was closed before Holman could fulfill his promise, blocking a completed act but not nullifying attempt.
  • Deputy Attorney General claimed no credible evidence existed, likely due to the investigation's dismissal before completion.

Barriers to Accountability and Enforcement

  • Federal and Texas law enforcement are controlled by political allies of the Trump administration, reducing likelihood of prosecution.
  • Federal recourse is limited as long as the Justice Department is under partisan control.
  • State-level prosecution in Texas is possible if state laws were violated, but local political control makes action improbable.
  • Presidential pardons and Supreme Court rulings increase impunity for high-ranking officials.

Transparency and Evidence Release

  • Freedom of Information Act (FOIA) requests may be filed to obtain the alleged video of Holman accepting cash.
  • With the investigation closed, the usual DOJ grounds for withholding evidence ("ongoing investigation") no longer apply, potentially making release possible.

Statute of Limitations and Future Prosecution

  • Federal bribery statutes typically have a five-year statute of limitations.
  • The clock may not start until the last act of the alleged crime or until the investigation was closed, if the closure was corrupt.
  • Legal ambiguity exists due to rare litigation on these circumstances.
  • If a new administration takes office, prosecution may still be possible, depending on how courts interpret the timing and interruption of the statutory period.

Recommendations / Advice

  • Pursue FOIA requests for release of the Holman investigation evidence, given lack of ongoing inquiry.
  • Monitor legal developments affecting statutes of limitations for cases of interrupted or corruptly closed investigations.
  • Support independent media for continued reporting on accountability and legal oversight.

Questions / Follow-Ups

  • Will Texas state authorities act on potential violations of state bribery laws?
  • Will the video evidence from the FBI sting operation be released to the public?
  • How will courts interpret statutes of limitations in cases of corruption-interrupted investigations?