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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Example Input: CURIAM. Appellant, Roberto Trejo, was indicted for racketeering and conspiracy to commit racketeering. His predicate offenses included attempted first degree murder, shooting into a building, and three armed robberies with a firearm. He was also charged on substantive counts for the same five offenses. Trejo was acquitted on the racketeering, conspiracy, and shooting into a building charges, but convicted of attempted second degree murder with a firearm and the three armed robberies. We affirm on all issues raised in this appeal, including his fifty-year sentence. The United States Supreme Court’s ruling in Graham v. Florida, 560 U.S. 48, 130 S.Ct. 2011, 176 L.Ed.2d 825 (2010) does not apply to appellant’s sentence. See Guzman v. State, 110 So.3d 480, 483 (Fla. 4th DCA 2013) (<HOLDING>). As we did in Guzman, we certify conflict with 
 Holding statements: (A) holding that williams fiftyyear sentence is not a de facto life sentence in violation of graham (B) recognizing that njeither graham nor miller explicitly  apply to the functional equivalent of life without parole ie de facto life sentences (C) holding that the imposition of a life sentence on a juvenile does not violate the holding of roper (D) holding that graham which prohibited the imposition of a life without parole sentence on a juvenile offender who did not commit homicide does not apply to a lengthy termofyears sentence that might constitute a de facto life sentence (E) holding that double jeopardy clause does not prohibit imposition of death sentence in alabama despite life sentence in georgia in murdertrial arising from same homicide
Example Output: (D)

Example Input: intended to purchase the entire 9.69 acre parcel described in the purchase and sale agreement. These findings have support in the record. Based on the evidence, the trial court could reasonably have been persuaded that it was highly probable that the parties operated under a mutual mistake as to the description in the deed. [¶ 18] Roger also argues that the doctrine of merger by deed prohibits reformation. “The doctrine of merger by deed provides that once a ... deed is accepted it becomes the final statement of the agreement between the parties and nullifies all provisions of the purchase-and-sale agreement.” Bryan, 665 A.2d at 1022 (quotation marks omitted). Merger by deed, however, does not prohibit reformation upon proof of a mutual mistake of fact at the time of closing. Cf. id. (<HOLDING>). C. Joint Accounts [¶ 19] Roger contends that 
 Holding statements: (A) holding that because the purchase price typically is not included in the deed this term of the contract of sale is not merged with the deed (B) holding in part that party seeking reformation of deed must show the original intent or agreement of parties by clear and convincing evidence (C) holding merger by deed prohibits reformation when one of the parties learns of a mistake before closing and still signs the deed (D) holding that a beneficiary under a deed of trust was entitled to reformation of the grantors deed (E) recognizing that the right to seek reformation of a deed is limited to the original parties to the deed and their successors in title
Example Output: (C)

Example Input: [ ] resisting] or interfering] with a lawful arrest of the person or another.” Ohio Rev.Code § 2921.33. As we have already held that the officers lawfully arrested Harris, the sole question is whether the officers had probable cause to believe that he recklessly resisted or interfered with that arrest. A reasonable factfinder could conclude that Harris’s actions — his uncooperative attitude, attempts to “resist[] and try[] to get loose,” unwillingness to accompany the officers to the DEA office and confrontational and threatening statements and gestures — satisfy this requirement, despite the lack of an “actual struggle.” JA 131; see Hansen v. Westerville City Sch. Dist., Bd. of Educ., Nos. 93-3231/93-3303, 1994 WL 622153 at*6, 1994 U.S.App. LEXIS 31576, at *15 (6th Cir. Nov. 7, 1994) (<HOLDING>); see also Palshook, 120 F.Supp.2d at 651. 
 Holding statements: (A) holding that there is no  1983 cause of action for false arrest unless the arresting officer lacked probable cause (B) holding avoiding arrest is not the same as resisting arrest (C) holding that plaintiff had failed to show officers lacked probable cause to arrest and prosecute him for resisting arrest under ohio law when he pulled his arm away from the officer told him to get your paws off me and struggled with the arresting officers (D) holding that officer had probable cause to arrest for violation of ordinance and that officers failure to cite ordinance either orally or in his arrest report was irrelevant (E) holding that the defendant was placed in official detention when two police officers approached him and told him that he was under arrest as the defendant could not reasonably have believed that he was free to leave
Example Output:
(C)