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.

[Q]: v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (2007). Kyler Road Home Charles first argues on appeal that the circuit court erred by not awarding him an interest in the home on Kyler Road. Although he acknowledges that Myra had acquired this property prior to the marriage, he asserts that he is entitled to an interest in the home because | ^marital funds were used to reduce the debt on the properly and to make improvements. Our definition of marital properly excludes property acquired before the marriage. Ark.Code Ann. § 9-12-315(b)(1) (Repl.2009). However, we have long held that a non-owning spouse is entitled to some benefit when marital funds have been expended to improve or reduce the debt on the other spouse’s nonmarital property. See Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (1993) (<HOLDING>); Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d 
 Holding statements: (A) holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property (B) holding that assets acquired subsequent to separation are not considered marital property absent evidence that spouse used marital property to obtain them (C) holding that separate property may become marital property if spouse donates it to marital unit with intent at time of donation that property become marital (D) holding that the trial court erred in finding that marital property was the former wifes separate property based on a nonseparation agreement in which the former husband purported to relinquish any interest in the marital property (E) holding that circuit court erred in failing to consider that marital property in the form of marital earnings was used to pay debt against nonmarital property
[A]: holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property


[Q]: first time a party must specify the statute authorizing attorney’s fees is in the Rule 54 motion (unless otherwise provided by statute or court order). In Missouri, attorney’s fees are not recoverable from another party, except when a contract or statute allows it. Essex Contracting, Inc. v. Jefferson County, 277 S.W.3d 647, 657 (Mo. banc 2009). The second sentence of the Missouri commissions statute is such an exception to the general Missouri rule. Kraft v. Edwards, 946 S.W.2d 775, 776 (Mo.App.1997). The district judge’s ruling that there was no statutory basis for an award of attorney’s fees is erroneous as a matter of law. On remand, the district court should consider whether to award attorney’s fees. See Chem-Trend, Inc. v. Newport Indus., Inc., 279 F.3d 625, 631 (8th Cir.2002) (<HOLDING>). Because this case as tried addressed only 
 Holding statements: (A) recognizing discretion of district court in determining a fee award (B) holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained (C) recognizing district courts discretion to consider pending state charge in determining sentence (D) recognizing court discretion in determining reasonable fee under rule 11 (E) holding that attorneys fee award in a common fund case must be  reasonable under the circumstances
[A]: holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained


[Q]: is made in one state and accepted in another, we now recognize that elements of the transaction have occurred in each state.” Id. at 786-87. Following this approach, the court held that all of A.S. Goldmen’s offers to purchase stock had occurred in New Jersey, but the acceptance of such offers by non-New Jersey residents had occurred in the purchaser’s state of residence. See id. at 787 (“A contract between Goldmen in New Jersey and a buyer in New York does not occur ‘wholly outside’ New Jersey, just as it does not occur ‘wholly outside’ New York. Rather, elements of the transaction occur in each state....”). Accordingly, New Jersey appropriately could regulate “the aspect of the transaction that occurs within its boundaries,” id., but not that part which occurred out of state. See id. (<HOLDING>) (internal footnote omitted). In Carolina 
 Holding statements: (A) holding that a writ of execution under new jersey law is not an action against the consumer (B) holding that the new jersey blue sky law simply allows the bureau to regulate its half of the transaction  the offer that occurs entirely within the state of new jersey (C) recognizing that pennsylvania had no interest in denying its residents the greater damages available under new jersey consumer fraud statutes for claims against a new jersey seller (D) recognizing israel had no interest in denying its citizens the substantive advantages of new jersey defamation law in new jersey residents claims for defamation published in new jersey (E) holding purposeful and deliberate omission on enactment of new jersey sales and use tax of exemption found in new york counterpart act which served as the model for new jersey act
[A]:
holding that a writ of execution under new jersey law is not an action against the consumer