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.

Example Input: was merely a voidable act. They rely on Sikes v. Global Marine, Inc., 881 F.2d 176 (5th Cir.1989), rehearing denied by 888 F.2d 1388 (5th Cir.1989), in which the Fifth Circuit found that the filing of a complaint in violation of the stay was voidable but not void. Id. at 178-79. The court reasoned that provisions of the Bankruptcy Code such as section 362(d), by giving courts the power to grant retroactive relief from a stay, indicated Congressional intent that acts in violation of a stay be simply voidable. Id. Spring Meadows, however, urges us to adopt the rule of the Ninth Circuit that any act committed in violation of an automatic stay is void. Hillis Motors, Inc. v. Hawaii Auto. Dealers Ass’n, 997 F.2d 581, 586 (9th Cir.1993); In re Schwartz, 954 F.2d 569, 571-72 (9th Cir.1992) (<HOLDING>). The circuit court found such acts void even 
 Holding statements: (A) recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect (B) holding that violations of the automatic stay are void and rejecting the reasoning of sikes (C) holding judgment in violation of automatic stay void (D) holding that the automatic stay did not bar the filing of a proof of claim where the debtor actively litigated a separate action during the pending bankruptcy proceeding because to permit the automatic stay provision to be used as a trump card played after an unfavorable result was reached  would be inconsistent with the underlying purpose of the automatic stay (E) holding that an action taken in violation of the automatic stay is void ab initio
Example Output: recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect

Example Input: motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel’s alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993) 
 Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel
Example Output: holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage

Example Input: Center. v. National League of Postmasters of U.S., 497 F.3d 972, 974-75 (9th Cir.2007) (finding that Cedars-Sinai’s claims were not preempted because they were “predicated not on the [service benefits] plan” but on a separate contract between the carrier and the medical services provider). Plaintiffs claim that Plaintiff never received compensation for the emergency care of B.G. directly relates to the processing and administration of the enrollee’s covered claims which is governed by the Service Benefits Plan and the Contract between Blue Shield and OPM. Any obligation that Blue Shield could have to pay Plaintiff stems directly from the B.G.’s enrollment in the Service Benefit Plan and directly relates to the payment of B.G.’s benefits under the plan. See Hayes, 819 F.2d at 926 (<HOLDING>); Botsford, 314 F.3d at 396 (“Because the 
 Holding statements: (A) holding that tort claims arising out of the manner in which a benefit claim is handled are preempted by fehba (B) holding that breach of fiduciary duty claim was preempted by fehba (C) holding state law claims arising out of unions refusal to readmit union members preempted by  301 (D) holding that fehba does not completely preempt state law (E) holding that the plaintiffs state law claims are preempted by federal law
Example Output:
holding that breach of fiduciary duty claim was preempted by fehba