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: from the Fijian military,” was “robbed repeatedly,” had his temple burned by Fijian soldiers, and Fijian soldiers attacked his home and destroyed his property while his wife was home alone. See id. Significantly, the attacks were linked by the fact that they were all carried out by a common entity, as opposed to random acts of violence that this court has characterized as the “common byproduct of civil unrest and economic turmoil.” See Gormley v. Ashcroft, 364 F.3d 1172, 1177 (9th Cir.2004). The acts described by Kumar are closer to those in Gormley. Therefore, the evidence does not compel a finding of persecution. Nor did Kumar present evidence that would compel “any reasonable adjudicator” to find that he demonstrated a likelihood of future persecution. See Wakkary, 558 F.3d at 1061 (<HOLDING>). Because Kumar’s evidence did not compel a 
 Holding statements: (A) holding that to show an objectively reasonable fear of future persecution an applicant must establish that he would be singled out for persecution or that there was a pattern or practice of persecution of similarlysituated individuals (B) holding that personal disputes do not constitute persecution (C) holding that evidence that  is consistent with acts of private violence  or that merely shows that a person has been the victim of criminal activity does not constitute evidence of persecution based on a statutorily protected ground (D) holding that while widespread violence against a protected group by private individuals and public officials may constitute persecution widespread discrimination that may include persecution of some individuals does not compel such a finding (E) holding that absent a pattern of persecution linked to the applicant persecution of family members is insufficient to demonstrate a wellfounded fear of persecution
Example Output: holding that to show an objectively reasonable fear of future persecution an applicant must establish that he would be singled out for persecution or that there was a pattern or practice of persecution of similarlysituated individuals

Example Input: cap in determining the amount of benefits another person was able to receive. Id. at 615. Although in Parisi, the child was suffering from the technical entitlement, the case stands for the proposition that a technical entitlement of zero should be counted as zero when computing family máximums. Considering that the purpose of the family maximum is to set a maximum that can be given from one wage earner’s account, Parisi complies with this purpose. IV. BY CITING PARISI, HAS PLAINTIFF RAISED A NEW ISSUE THAT IS NOT PROPERLY INCLUDED IN THIS JUDICIAL REVIEW? “[I]f petitioner wishes to preserve an issue for appeal, he must first raise it in the proper administrative forum_” Tejeda-Mata v. INS, 626 F.2d 721, 726 (9th Cir.1980); See Chung Young Chew v. Boyd, 309 F.2d 857, 861 (9th Cir.1962) (<HOLDING>). Yet, in Tejeda-Mata the court held this “in 
 Holding statements: (A) recognizing that failure to observe the required process deprives the court of jurisdiction (B) holding that the court lacked jurisdiction over the petition for review because the aliens did not appeal the ijs denial of their motion to reopen to the board resulting in failure to exhaust their administrative remedies (C) holding that partys failure to file a timely internal administrative appeal as required by regulations of the department of agriculture constituted failure to exhaust administrative remedies and precluded judicial action (D) recognizing that failure by state to provide the required certification deprives appeals court of jurisdiction over appeal (E) holding that failure to take available appeal to board of immigration appeals constitutes failure to exhaust administrative remedies and deprives the court of appeals of jurisdiction to review
Example Output: recognizing that failure to observe the required process deprives the court of jurisdiction

Example Input: acted to remove the children from the Mann home. Defs. Mot. 10. “[Government officials performing discretionary functions generally are shielded from liability for civil dam ages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 73 L.Ed.2d 396 (1982); see also Malley v. Briggs, 475 U.S. 335, 341, 106 S.Ct. 1092, 89 L.Ed.2d 271 (1986). Thus, on summary judgment, a court “appropriately may determine, not only the currently applicable law, but whether that law was clearly established at the time an action occurred.” Harlow, 457 U.S. at 818, 102 S.Ct. 2727; see also Davis v. Scherer, 468 U.S. 183, 183, 104 S.Ct. 3012, 82 L.Ed.2d 139 (1984) (<HOLDING>). “If, the law was clearly ' established, the 
 Holding statements: (A) recognizing a cause of action for damages against officials who violate constitutional or statutory rights under color of federal law (B) recognizing cause of action against federal officials for violation of constitutional rights (C) holding that a plaintiff who seeks damages for violation of constitutional or statutory rights may overcome the defendant officials qualified immunity only by showing that those rights were clearly established at the time of the conductat issue (D) holding that defendant is entitled to qualified immunity because plaintiff failed to allege the violation of a clearly established constitutional right (E) recognizing that qualified immunity shields officials unless the plaintiff demonstrates the defendant violated a constitutional right that was clearly established
Example Output:
recognizing a cause of action for damages against officials who violate constitutional or statutory rights under color of federal law