instruction:
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.
question:
§ 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the § 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA’s one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this § 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, — U.S. -, 121 S.Ct. 78, 148 
 Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
answer:
holding that issues not raised before the district court cannot be raised for the first time before this court


question:
of the debtor. This distinction appears immaterial under the language of sec. 409.402(7), Stats. 7 In other contexts, a security interest properly perfected at one time may later become unperfected through creditor inaction. See, e.g. sec. 409.103(l)(d)l, (2)(b), (3)(e), Stats, (four month grace periods preserving perfection in collateral removed from jurisdic tion); sec. 409.403(2) (lapse of financing statements after 5 years unless continued). 8 Interestingly, the Ansley court held that a filing under "the name Ansley Farms instead of the debtor's true name — Emory Ansley — is seriously misleading, making [the]. . . security interest unperfected.. . ." Id,., 467 F.Supp. at 55. Other cases reaching similar results are In Re Wishart, 10 U.C.C. Rep. Serv. 1296 (Bankr.W.D. Mich. 1972) (<HOLDING>); In Re Brawn, 7 U.C.C. Rep. Serv. 565 (D.C. 
 Holding statements: (A) holding that the filing of notice without motion is insufficient (B) holding a filing under mccauleys reprographics and mapping insufficient to perfect a security interest in the assets of the debtor corporation (C) holding that the reservation of a claim need not name a defendant but only identify the type of claim the debtor seeks to retain (D) holding a filing under wishart equipment co insufficient to identify the debtor horace wishart (E) holding a filing under john and mayella lintz insufficient to identify the debtor corporation
answer:
holding that the filing of notice without motion is insufficient


question:
2010 WL 877569, at *3; Hart, 1999 WL 225956, at *2). The court reasoned that because Samshi Homes acknowledged that the documents filed by De Leon were in the form of mechanics liens, the documents were instruments “provided by the ... laws of this state” and were “therefore not presumed to be fraudulent under section 51.901(c)(2)(A).” Id. The court concluded, “Samshi Homes[’s] complaints based on section 53.054 are therefore beyond the scope of the current proceedings.” Id. at 668. The court further concluded that “Sam-shi Homes’ substantive evidentiary claims — that it, rather than Kama, owned the subject properties and that Kama never entered into an agreement with De Leon — are also beyond the scope of the section 51.903 proceedings.” Id. (citing Becker, 2010 WL 877569, at *3 (<HOLDING>)). Although it is factually distinct from the 
 Holding statements: (A) holding that the declaratory judgment act is remedial only and the party seeking declaratory relief must have an underlying cause of action (B) holding that an injured party in an underlying tort action was not a necessary party in an action by an insurer for declaratory judgment of nonliability where the injured person had not obtained judgment against the insured (C) holding that movant converted his motion for judicial review into an action seeking declaratory judgment by requesting rulings on underlying rights of the parties (D) holding that a motion for a summary judgment is an appropriate means of seeking an adjudication on the merits (E) holding that where the question to be resolved in the declaratory judgment action will be decided in a pending action it is inappropriate to grant a declaratory judgment
answer:

holding that the declaratory judgment act is remedial only and the party seeking declaratory relief must have an underlying cause of action