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]: because of [the dealer’s] precarious financial condition .... ... [W]e decline to hold BMW/NA negligent and liable for damages since it could not reasonably have anticipated the crimes committed by [the dealer’s] principal, Eichler. Although BMW/NA may have been aware of [the dealer’s] shaky financial condition, that knowledge alone gave BMW/NA no cause reasonably to anticipate that Eichler would either engage in any criminal activity or that he would abscond with customer funds. In fact, no amount of supervision by BMW/NA would have enabled it to foresee Eichler’s thievery. Id. In other cases involving the franchisors of automobile dealerships, the courts have reached similar results. See Colson v. Maghami, No. CV 08-2150-PHX-MHM, 2010 WL 2744682, at *9-10 (D.Ariz. July 9, 2010) (<HOLDING>); DaimlerChrysler Motors Co., LLC v. Clemente, 
 Holding statements: (A) holding that owners and officers of automobile dealership who were neither consumers nor competitors in automobile market lacked standing to bring antitrust action against automobile manufacturer (B) holding that a franchisor had no duty to supervise its automobile dealership or to warn a customer of the dealership who paid a substantial deposit for a limited edition lamborghini reventon and who did not receive either the car or the return of his deposit (C) holding that an automobile dealership had no duty to prevent the misconduct of the executives of another company who misappropriated company funds to make the purchase of several automobiles from the dealership (D) holding that where no evidence was designated to show that a car buyer knew that a sale violated the rights of the dealership that owned the car the buyers were buyers in the ordinary course of business for purposes of indcode  26112019 (E) holding that a car dealership could be held vicariously liable for the intentional tort of its employee who shot out the tires of the plaintiffs truck during a repossession attempt
[EX A]: holding that owners and officers of automobile dealership who were neither consumers nor competitors in automobile market lacked standing to bring antitrust action against automobile manufacturer

[EX Q]: 398, 407 (1988) (concluding that the act of inserting an adult’s tongue into a child’s mouth constituted an “immoral, improper, or indecent” act within the meaning of N.C.G.S. § 14-202.1(a)(1) and a “lewd or lascivious” act within the meaning of N.C.G.S. § 14-202.1(a)(2)); State v. Hammett, 182 N.C. App. 316, 323, 642 S.E.2d 454, 459 (concluding that masturbating in a child’s presence constituted an offense punishable pursuant to N.C.G.S. 14-202.1(a)(2)), appeal dismissed and disc. rev. denied, 361 N.C. 572, 651 S.E.2d 227 (2007); State v. Turman, 52 N.C. App. 376, 377, 278 S.E.2d 574, 575 (1981) (concluding that masturbating in a child’s presence constituted an offense pursuant to N.C.G.S. § 14-202.1(a)(l)); cf. State v. Jones, 172 N.C. App. 308, 314-16, 616 S.E.2d 15, 19-20 (2005) (<HOLDING>). In light of these decisions, at least four 
 Holding statements: (A) holding that single substantial act can support exercise of personal jurisdiction (B) holding that multiple convictions under  924c cannot be based on offenses forming a single unit of prosecution (C) holding that a single act cannot support two convictions under both ncgs  142021al and ncgs  142021a 2 respectively (D) recognizing that dui manslaughter and vehicular homicide are two separate crimes neither being a lesser included offense of the other but holding that a single death cannot support convictions for both crimes (E) holding that separate sentences may be imposed for a violation of section 36bd and the predicate offense where both convictions were the result of the same act so long as the charges are brought in a single trial
[EX A]: holding that single substantial act can support exercise of personal jurisdiction

[EX Q]: 14 F.3d at 1500. We conclude that it does not. Courts have recognized that the act of reopening a closed bankruptcy case does not afford the parties any substantive relief. Woods, 173 F.3d at 777 (quoting DeVore v. Marshack (In re DeVore), 223 B.R. 193, 198 (9th Cir. BAP 1998), for the proposition that “[t]he reopening of a case is ‘merely a ministerial or mechanical act [that] ... has no independent legal significance and determines nothing with respect to the merits of the case.’ ”); see Cusano v. Klein, 264 F.3d 936, 948 (9th Cir.2001) (noting that order reopening closed case “ ‘lacks independent legal significance and determines nothing with respect to the merits of the case’ ”) (quoting Menk v. LaPaglia (In re Menk), 241 B.R. 896, 913 (9th Cir. BAP 1999)); Paine, 250 B.R. at 107 (<HOLDING>). Indeed, “ ‘[t]he effect of [11 U.S.C. § 
 Holding statements: (A) holding that department does not have independent authority to impose device in absence of court order (B) recognizing that an order reopening a closed case was simply a mechanical device that did not afford or deny the debtors any affirmative relief (C) holding that court lacked jurisdiction on appeal from injunction because the order was simply an interpretation of an earlier order (D) recognizing laches as an affirmative defense (E) recognizing that a defendant may not insist on representation by an attorney he cannot afford
[EX A]:
holding that department does not have independent authority to impose device in absence of court order