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: Chief Judge: The appellant, Craig G. Falk, appeals from a July 8, 1996, Board of Veterans’ Appeals (BVA or Board) decision denying his claim service connection for post-traumatic stress disorder (PTSD). As the appellant has limited his appeal to the denial of that claim, the Court deems the appellant to have abandoned his right to appeal with respect to the denial of entitlement to benefits under 38 U.S.C. § 1151. Bucklinger v. Brown, 5 Vet.App. 435, 436 (1993); see also Carbino v. West, 168 F.3d 32, 34-35 (Fed.Cir.1999) (<HOLDING>). Upon consideration of the pleadings of the 
 Holding statements: (A) holding that an issue not presented to the trial court will not be considered on appeal (B) holding that issues not presented in an appellants initial brief to the court need not be considered under this courts rules (C) holding that claims not raised in an appellants initial brief to our court are waived (D) holding that issues not raised in an appellants initial brief are deemed abandoned (E) holding an appellant may not use the reply brief to argue issues not argued in the initial brief
Example Output: holding that an issue not presented to the trial court will not be considered on appeal

Example Input: plain error review because he did not object to the admissibility of the reports or to the testimony by Detective Duft about the report. See State v. Parker, 350 N.C. 411, 427, 516 S.E.2d 106, 118 (1999) (plain error is error “so fundamental as to amount to a miscarriage of justice or which probably resulted in the jury reaching a different verdict than it otherwise would have reached.”). Indeed, Defendant never disputed that the material was cocaine. He chose not to defend on that basis, but rather focused on portraying himself as a homeless person making a delivery in exchange for beer and cigarettes. Since the identity of the substance was not challenged, the admission of the laboratory reports was harmless error. See State v. Edwards, - N.C. App. -,-, 621 S.E.2d 333, 337 (2005), (<HOLDING>); State v. Thompson, 110 N.C. App. 217, 225, 
 Holding statements: (A) holding that trial delay for dna testing was attributable to the state but was mere negligence (B) holding that failure to require production of dna testing protocols was harmless beyond a reasonable doubt when the defendant did not dispute that he committed the crimes at issue but rather argued that he was mentally impaired (C) holding that the sixth amendment confrontation clause violation in that case was harmless beyond a reasonable doubt and therefore did not require the conviction to be overturned (D) holding that harmless beyond a reasonable doubt analysis not applicable in habeas cases (E) holding the state failed to meet its burden of showing the erroneous jury instruction was harmless beyond a reasonable doubt where it did not address the issue on appeal
Example Output: holding that trial delay for dna testing was attributable to the state but was mere negligence

Example Input: 978 S.W.2d 612, 618 (Tex.App.-Corpus Christi 1998, pet. denied) (considering apartment complex and neighborhood surrounding complex). Finally, Barton’s contention that Whataburger’s earlier employment of a security guard on the weekends proves the foreseeability of the robbery is unavailing. “The mere act of taking preventative measures to protect against the possibility of future crime is not the same as foreseeing that criminal activity.” Allen, 158 S.W.3d at 67. If we equated preventative measures to foreseeability, we would “virtually eliminate the foreseeability requirement for a negligence claim against a person who installs a security system or takes other preventative measures to guard against crime.” Id.; accord Stewart, 214 S.W.3d at 665; Garcia, 203 S.W.3d at 437-38 (<HOLDING>). Applying the Timberwalk factors of proximity, 
 Holding statements: (A) holding that murder committed by customer was not foreseeable result of excessive sale of alcohol to customer (B) holding that a defendant may be convicted of felony murder when the death of his accomplice was a reasonably foreseeable result of their commission of a felony (C) holding that criminal conduct on premises was not foreseeable (D) holding that targeted murder committed on premises of sonic restaurant was not foreseeable result of sonics failure to employ security guard (E) holding that murder committed by minor gang members was not foreseeable result of sale of alcohol to gang members
Example Output:
holding that murder committed by customer was not foreseeable result of excessive sale of alcohol to customer