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]: to landslide, even though earth movement was the most immediate cause). We therefore conclude that this is a case of multiple causation. B. We must now determine whether the deterioration or the fungicide manufacturers’ failure to warn is the “proximate efficient cause” of the damage to Berry’s irrigation pipes. In Sabella, the California Supreme Court defined “proximate efficient cause” both as “the one that sets others in motion” and as “the predominating or moving efficient cause.” Sabella, 27 Cal.Rptr. at 695, 377 P.2d at 895; see Garvey, 257 Cal.Rptr. at 296, 770 P.2d at 708 (“Sabella defined ‘efficient proximate cause’ alternatively as the ‘one that sets others in motion’ and as ‘the predominating or moving efficient cause.’”) (citations omitted); Howell, 267 Cal.Rptr. at 716 (<HOLDING>); Brian Chuchua’s Jeep, 13 Cal.Rptr.2d at 445 
 Holding statements: (A) recognizing the existence of purely jurisdictional elements (B) recognizing existence of two tests (C) recognizing first two exceptions (D) recognizing that the existence of an agency relationship is ordinarily a question of fact (E) recognizing the existence of the special relationship
[EX A]: recognizing the existence of purely jurisdictional elements

[EX Q]: rise to the level of the allegations in Harke-ma. While physical abuse obviously endangers a child, Ma Donna’s account of her January 1997 fight with F.G. is not inconsistent with F.G.’s charge (except for the allegation of hair-pulling). An alleged single incident of borderline abuse or neglect has been held not to constitute sufficient endangerment to warrant a custody modification. See Smith, 508 N.W.2d at 227 (insufficient endangerment where child was injured by fallen cuckoo clock and mother allegedly examined clock before child). Under the circumstances, the court did not abuse its discretion in giving this incident little weight. This court has been inconsistent in categorizing a custodial parent’s efforts to isolate the child from relatives. Compare Westphal, 457 N.W.2d at 229 (<HOLDING>) with Smith, 508 N.W.2d at 227 (stating that a 
 Holding statements: (A) holding that postadoption visitation of child who was adopted by grandparents on basis of biological parents unconditional consent was required to promote childs best interests (B) holding that paramount consideration in terminationofparentalrights proceeding is best interests of the child (C) holding mothers cutting off contact with grandparents to be best interests consideration but not evidence of endangerment (D) holding that best interests of the child analysis requires consideration of all section 5328a factors (E) holding unconstitutional a statute authorizing courts to recognize grandparents as having the same standing as parents for evaluating what custody arrangements are in the best interest of the child where the child actually resided with the grandparents in a stable relationship
[EX A]: holding that postadoption visitation of child who was adopted by grandparents on basis of biological parents unconditional consent was required to promote childs best interests

[EX Q]: vehicle cases under the [Policitical Subdivisions Tort Claim] Act has been the involvement of the motor vehicles as motor vehicles in accidents. In no cited case has a waiver to immunity been found where the plaintiff has alleged the sole involvement of the governmental motor vehicle lay in carrying a passenger to an area for discharge that the governmental agency knew or should have known was unsafe. The Complaint alleges the bus driver did nothing wrong other than allowing [appellant] to leave the bus in a certain place. The Comp ne whether Paula Jo Lehman continued to be an “occupant” of the bus after she had alighted from the bus and was crossing the street behind the bus to get to her school. See Walker v. Port Authority of Allegheny County, 323 Pa.Super. 427, 470 A.2d 993 (1984) (<HOLDING>). Assuming, without deciding, that she was no 
 Holding statements: (A) holding port authority required to provide basic loss benefits under section 204a4 of nofault act regardless of whether passenger continued to be occupant as bus was involved in an accident when passenger struck by passing vehicle after alighting from bus (B) holding police incident to arrest of occupant of automobile may search entire passenger compartment of vehicle (C) holding that ttcas motorvehicle waiver did not apply to claim whose gravamen was that bus drivers failure to supervise the public  by for example failing to supervise tortfeasor passenger and failing to return to pick up victim passenger  allowed tortfeasor who had threatened victim on bus to assault victim after both had exited (D) holding that after making an arrest of the driver of a vehicle the police may search the passenger compartment of the vehicle (E) holding that fourth amendment rights of a passenger of a legally stopped vehicle were not violated by police officers instruction that he remain inside the vehicle during traffic stop after passenger repeatedly tried to exit
[EX A]:
holding police incident to arrest of occupant of automobile may search entire passenger compartment of vehicle