In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[EX Q]: Brown’s argument that she was speaking as a citizen is supported by the fact that ordinary citizens may similarly report public misconduct to the Auditors. See Conn. Gen. Stat. § 4-61dd (conferring right to file reports with Auditors on “any person”). The existence of a civilian analogue to Brown’s conduct strengthens her allegations that her speech was as a citizen and thus protected by the First Amendment. See Matthews I, 779 F.3d at 176. The instant case is not similar to other cases of its type that were dismissed at the motion to dismiss stage. In many of those cases, the plaintiff-employee had made an admission that the alleged speech was made, at least in part, pursuant to his or her official duties. See Matthews v. Lynch, 483 Fed.Appx. 624, 626 (2d Cir. 2012) (Matthews III) (<HOLDING>); Anemone, 629 F.3d at 116. Here, there is no 
 Holding statements: (A) holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel (B) holding that a plaintiff did not complain to the eeoc pursuant to official duties but rather as a citizen (C) holding that pursuant to garcetti plaintiffs speech made in the course of his official duties was unprotected as a matter of law (D) holding that speech was pursuant to official duties because plaintiff conceded at oral argument that as an internal affairs officer he had a broad responsibility to investigate and report police misconduct (E) holding police officer is a public official
[EX A]: holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel

[EX Q]: before section 362(b)(3) can come into play. An act that both creates and perfects a lien postpetition cannot so qualify. See, e.g., Louisville & Jefferson County Metro. Sewer Dist. v. Excel Eng’g, Inc. (In re Excel Eng’g, Inc.), 224 B.R. 582, 589-90 (Bankr.W.D.Ky.1998) (refusing to recognize validity of postpetition creation and perfection of mechanic’s hen because creditor had no lien at the time debtor filed for bankruptcy); Water-vliet Paper Co. v. City of Watervliet (In re Shoreham Paper Co.), 117 B.R. 274, 281-83 (Bankr.W.D.Mich.1990) (finding postpe-tition creation and perfection of property tax lien barred by automatic stay because no prepetition interest existed); Equitable Life Assur. Soc’y v. Ballentine Bros. (In re Ballentine Bros.), 86 B.R. 198, 201 (Bankr. D.Neb.1988) (<HOLDING>); North Side Lumber Co. v. Indus. Indem. Co. 
 Holding statements: (A) holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations (B) holding that the automatic stay would be modified so that a credit union could seek payment of postpetition interest from the codebtor (C) holding judgment in violation of automatic stay void (D) holding that creditors failure to voluntarily turn over property lawfully seized prepetition constituted violation of automatic stay (E) holding that creation of a postpetition tax levy based on a prepetition assessment was barred by the automatic stay
[EX A]: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations

[EX Q]: various policymaking county officials who “combined to create an official County policy of illegal retaliation against plaintiffs based on racial motivations.” See Plaintiffs’ Opposing Memorandum, pg. 21. In plaintiffs view, evidence of this retaliatory policy is established primarily by initially awarding the GPP contract to another vendor (although plaintiffs were ultimately awarded the contract), ordering minuscule amounts of the product, and a derogatory statement made by Rodriguez, an individual who is not even a party to this case. These incidents, however, fail to constitute a custom or policy of retaliation “so permanent and well settled ... with the force of law.” See City of St. Louis v. Praprotnik, supra. See e.g., Hamilton v. Rodgers, 791 F.2d 439, 443 (5th Cir.1986) (<HOLDING>). Moreover, plaintiffs fail to present any 
 Holding statements: (A) holding that two separate incidents of rape were perpetrated against the same victim where an appreciable period of time elapsed between the incidents and intervening events occurred during the interim (B) holding that a dozen racial incidents over a two and one half year period were too few to constitute a custom with the force of law (C) holding that five alleged incidents in four years were too few too separate in time and too mild  to create an abusive working environment (D) holding that two incidents of alleged excessive force are insufficient to show policy or custom (E) holding that only two overtly racial comments and one arguably racial remark over the course of the plaintiffs eight years of employment did not constitute pervasive conduct
[EX A]:
holding that two separate incidents of rape were perpetrated against the same victim where an appreciable period of time elapsed between the incidents and intervening events occurred during the interim