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.

[Q]: in which this Court's authority to review criminal convictions was greatly circumscribed.” Cotton, 535 U.S. at 629, 122 S.Ct. 1781. It could examine constitutional errors in a criminal trial only on a writ of habeas corpus, and only then if it deemed the error "jurisdictional.” Id. (internal quotation marks omitted). "The Court’s desire to correct obvious constitutional violations led to a 'somewhat expansive notion of jurisdiction.Id. (quoting Custis v. United States, 511 U.S. 485, 494, 114 S.Ct. 1732, 128 L.Ed.2d 517 (1994)) (internal quotation marks omitted). 25 . A charging instrument may be so deficient that a court does not have jurisdiction over the case; for instance, if the charging document was never filed. See State v. Kaulia, 128 Hawai'i 479, 491, 291 P.3d 377, 389 (2013) (<HOLDING>). Without deciding the matter, a charge that 
 Holding statements: (A) holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted (B) holding that an action brought against the state officials in their official capacities was not properly removed to federal court because the district court lacked jurisdiction (C) holding that the appellate court had jurisdiction to hear the interlocutory appeal on a restraining order and the district court retained jurisdiction to proceed with the trial (D) holding that the district court lacked jurisdiction to review state disciplinary proceedings against attorney (E) holding that because the state failed to properly file the complaint the district court lacked jurisdiction to proceed to trial
[A]: holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted


[Q]: If a statement does not contain any expressly exculpatory material, the Government need not produce that statement to the defense. To hold otherwise would impose an insuperable burden on the Government to determine what facially non-exculpatory evidence might possibly be favorable to the accused by inferential reasoning. We are confident that the Supreme Court did not intend the Brady holding to sweep so broadly. United States v. Comosona, 848 F.2d 1110, 1115 (10th Cir.1988); see also Harris v. Kuba, 486 F.3d 1010, 1016 (7th Cir.2007) {“Brady does not require that police officers or prosecutors explore multiple potential inferences to discern whether evidence that is not favorable to a defendant could become favorable.”); United States v. Marrero, 904 F.2d 251, 261 (5th Cir.1990) (<HOLDING>). The Court finds that just such inferential 
 Holding statements: (A) holding that the presentation of a new theory does not constitute the presentation of a new issue on which a jury trial should be granted as of right under  rule 38b (B) holding that there is no constitutional duty to do a better investigation and that a decision not to conduct a more thorough investigation does not invade an accuseds rights (C) holding that the burden is on the plaintiff (D) holding that the burden is upon the state under the applicable federal rules of evidence (E) holding that brady does not place any burden upon the government to conduct a defendants investigation or assist in the presentation of the defenses case
[A]: holding that the presentation of a new theory does not constitute the presentation of a new issue on which a jury trial should be granted as of right under  rule 38b


[Q]: in part. As the Majority explains, the “implied bias [doctrine] remains available, in appropriate circumstances, to disqualify jurors whose connection with the litigation makes it highly unlikely that they can remain impartial adjudicators.” (Slip Op. at 13 (citing United States v. Calabrese, 942 F.2d 218 (3d Cir. 1991)).) In dicta in Calabrese, we cited with approval Justice O’Connor’s observation in Smith v. Phillips, 455 U.S. 209, 102 S. Ct. 940, 71 L. Ed. 2d 78 (1982), that a “juror [who] is an actual employee of the prosecuting agency” is one example of an “extreme situation^ that would justify a finding of implied bias.” Calabrese, 942 F.2d at 226 (quoting Smith, 455 U.S. at 222 (O’Connor, J., concurring)); accord United States v. Polichemi, 201 F.3d 858, 861-64 (7th Cir. 2000) (<HOLDING>). It is true, as the Majority says, that Juror 
 Holding statements: (A) holding that the failure to strike potentially biased juror was not iac where decision was based on trial strategy (B) holding that where a claim of ineffective assistance of counsel is grounded in the claim that counsel failed to strike a biased juror a defendant must show that the juror was actually biased against him (C) holding that the attorney generals decision not to provide representation to an employee is reviewable by the appellate division not by the law division where the actions against the employee are pending (D) holding that the district court did not abuse its discretion when the trial judge questioned the juror extensively enough to satisfy itself that the juror was not biased emphasis added (E) holding without citing to justice oconnors concurrence in smith that a juror who was a 15year secretarial employee in the civil division of the prosecuting agency was impliedly biased
[A]:
holding that the failure to strike potentially biased juror was not iac where decision was based on trial strategy