Judge Holden is purportedly a historical person, a murderer who partnered with John Joel Glanton as a professional scalphunter in the mid-19th century. To date, the only source for Holden's existence is Samuel Chamberlain's My Confession, an autobiographical account. Chamberlain described Holden as well-spoken, intelligent and physically quite large. He also described Holden as perhaps the most ruthless of the roving band of killers led by Glanton.