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]: in which this Court's authority to review criminal convictions was greatly circumscribed.” Cotton, 535 U.S. at 629, 122 S.Ct. 1781. It could examine constitutional errors in a criminal trial only on a writ of habeas corpus, and only then if it deemed the error "jurisdictional.” Id. (internal quotation marks omitted). "The Court’s desire to correct obvious constitutional violations led to a 'somewhat expansive notion of jurisdiction.Id. (quoting Custis v. United States, 511 U.S. 485, 494, 114 S.Ct. 1732, 128 L.Ed.2d 517 (1994)) (internal quotation marks omitted). 25 . A charging instrument may be so deficient that a court does not have jurisdiction over the case; for instance, if the charging document was never filed. See State v. Kaulia, 128 Hawai'i 479, 491, 291 P.3d 377, 389 (2013) (<HOLDING>). Without deciding the matter, a charge that 
 Holding statements: (A) holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted (B) holding that an action brought against the state officials in their official capacities was not properly removed to federal court because the district court lacked jurisdiction (C) holding that the appellate court had jurisdiction to hear the interlocutory appeal on a restraining order and the district court retained jurisdiction to proceed with the trial (D) holding that the district court lacked jurisdiction to review state disciplinary proceedings against attorney (E) holding that because the state failed to properly file the complaint the district court lacked jurisdiction to proceed to trial
[A]: holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted


[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]: award plaintiff more than $18,513 and that it was to subtract from that amount any income actually earned by plaintiff after he left defendant. Defendant’s position at trial was that it fired plaintiff for just cause, i.e., his continual inability to get along with his coworkers. The jury was presented with a jury verdict form that permitted it to award the verdict to defendant and, instead, it rendered a verdict for plaintiff and awarded damages. Our examination of the evidence and the parties’ positions at trial in light of the jury’s verdict persuades us that it is more likely than not that the court’s instruction created an erroneous impression of the law in the minds of the jury that affected its award. ORS 19.125(2). See also Baker v. English, 324 Or 585, 590, 932 P2d 57 (1997) (<HOLDING>). Reversed and remanded. 1 Three of those 
 Holding statements: (A) recognizing under plain error review that the burden to show that substantial rights have been prejudiced is on the party that failed to raise the issue below and for an error to have affected substantial rights the error must have affected the outcome of the district court proceedings (B) holding that the affecting substantial rights language of rule 52b means that the error must have been prejudicial it must have affected the outcome of the district court proceedings (C) holding that the outcome of the case could have been different if the trial court had imposed the appropriate burden (D) holding that a petitioner must show  that the outcome of his appeal would have been different had counsel raised the issue (E) holding that the rights of an aggrieved party are substantially affected if the outcome either would have or may have been different had the error not occurred
[A]:
recognizing under plain error review that the burden to show that substantial rights have been prejudiced is on the party that failed to raise the issue below and for an error to have affected substantial rights the error must have affected the outcome of the district court proceedings