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]: (citations omitted). Kaul believes that because the Court did not include seizing cigarettes fi*om Indians inside a reservation on this list, Stephan lacked jurisdiction to execute the search warrant at Kaul’s store. However, we do not read Oklahoma Tax Commission and Colville as necessarily prohibiting state officers from conducting search and seizure operations within a reservation’s borders under the authority of a federal grant of criminal jurisdiction to the state. Instead, these opinions merely offer several options that state officials may employ to enforce regulatory cigarette tax statutes. Here, Kaul waived the argument that the Kansas statute was regulatory in nature because she did not raise that issue below. Thus, for purposes of this appea 3, 2061, 109 L.Ed.2d 693 (1990) (<HOLDING>). Furthermore, the Supreme Court has long held 
 Holding statements: (A) holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction (B) recognizing the inherent power of indian tribes  to exercise criminal jurisdiction over all indians (C) holding that indian tribes lack tribal jurisdiction over crimes committed by nonmember indians within the tribes reservation (D) holding that indian tribes could only exercise criminal jurisdiction over tribal members and not other indians (E) holding that an indian tribes exercise of criminal jurisdiction over nonindians is inconsistent with the domesticdependent status of the tribes and that tribes may not assume such jurisdiction without congressional authorization
[EX A]: holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction

[EX Q]: Rodrigues hit him in the head with a hand-held radio. Defendant Rodrigues ordered Barile to tell the doctors at the hospital that he injured himself in a “fall.” Subsequently, Barile made a complaint to the Internal Affairs Division and an investigator was assigned to verify Barile’s claim. On June 11, 1997, a private attorney informed Barile that the law firm had filed a Notice of Intent to sue the City of Hartford. On April 13, 2004, the cessive force against him on December 21, 1996. Thus, Barile had until December 21, 1999, to file his complaint. When considering a ease filed by a prisoner, the courts consider a complaint to have been filed as of the date the inmate gives the complaint to prison officials to be mailed to the court. See Dory v. Ryan, 999 F.2d 679, 682 (2d Cir.1993) (<HOLDING>) (citing Houston v. Lack, 487 U.S. 266, 270, 
 Holding statements: (A) holding that prisoners notice of appeal is deemed filed on date he delivered it to prison officials for mailing to court (B) holding that an noa filed by a pro se prisoner is deemed filed on the date that the prisoner delivers it to prison authorities for mailing (C) holding that prisoners notice of appeal deemed filed on date he delivered it to prison officials for mailing to court (D) holding that the date of filing is the time at which a pro se prisoner entrusts the document to prison officials for delivery (E) holding that a pro se prisoner complaint is deemed filed as of the date the prisoner gives the complaint to prison officials to be forwarded to the court
[EX A]: holding that prisoners notice of appeal is deemed filed on date he delivered it to prison officials for mailing to court

[EX Q]: 15.7(a)’s general grant of authority, skirts the more stringent requirements of the contempt remedy authorized by Rule 15.7(a)(3). ¶ 51 Neither can the majority’s holding be explained as an exercise of its inherent authority apart from Rule 15.7. In Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240, 257-58, 95 S.Ct. 1612, 44 L.Ed.2d 141 (1975), the United States Supreme Court affirmed the continuing vitality of the “American Rule” that requires each party to bear the cost of its own attorneys’ fees absent express statutory authority except in the following exceptional circumstances: (1) the common fund doctrine applies; (2) a party willfully disobeys a court order; or (3) a party acts in bad faith. See also Zambrano v. City of Tustin, 885 F.2d 1473, 1482 (9th Cir.1989) (<HOLDING>) (footnote omitted). ¶ 52 Similarly, in 
 Holding statements: (A) holding that absent explicit congressional authorization the factual prerequisites of bad faith misconduct or willful disobedience laid out in alyeska must be met (B) holding that a bad faith claim is a tort (C) holding that remedial scheme afforded by federal tort claims act was not exclusive absent explicit congressional declaration that it was (D) holding that a bad faith claim must be met through the clear and convincing evidence standard (E) holding that a bad faith claim arises out of contract for attorney fee statute
[EX A]:
holding that a bad faith claim is a tort