He submitted in the guest category. The rule used to be that if an actor was on a show for more than 6 episodes it was ineligible for the guest category and had to be submitted in the supporting. Lithgow (like Jimmy Smits before him) took advantage of the rule's recent abolition and decided to compete in the "easier" guest category. Lithgow's character on Dexter had more of a presence and more screentime than even some recent supporting actor nominees (he won the Golden Globe for Best Supporting Actor in Television). So I won't be too surprised if the Academy announces that they're reinstating the 6-episode rule.
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