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: to those sentences because no error in the sentencing appears on the face of the record. Ninety-nine years is a “term of years not less than five years.” While Thomas’ sentences, under court interpretations of § 566.030.2, may not be authorized, we are not able to reach such issues where the sentencing defect is not so patent as to present a jurisdictional issue. This sentencing does not present a jurisdictional issue. Conclusion Thomas is ordered to be returned to the circuit court of the City of St. Louis for resentencing on the three first degree robbery counts within the limits authorized by the law. SO ORDERED. All concur. 1 . All sectional references are to Missouri Revised Statutes 1986, unless otherwise indicated. 2 . See, e.g., State v. Williams, 828 S.W.2d 894 (Mo.App.1992)(<HOLDING>); State v. Charron, 743 S.W.2d 436 
 Holding statements: (A) holding that a defendants sentence was reasonable in part because it was well below the statutory maximum (B) recognizing a claim that the sentence exceeded the statutory maximum (C) holding sentence of thirtyfive years in prison with ten years probation for seconddegree murder is within the statutory maximum under 1997 statutes (D) holding that the sentence was reasonable in part because it was well below the statutory maximum (E) holding sentence of 100 years for forcible rape was in excess of statutory maximum
Example Output: holding that a defendants sentence was reasonable in part because it was well below the statutory maximum

Example Input: before section 362(b)(3) can come into play. An act that both creates and perfects a lien postpetition cannot so qualify. See, e.g., Louisville & Jefferson County Metro. Sewer Dist. v. Excel Eng’g, Inc. (In re Excel Eng’g, Inc.), 224 B.R. 582, 589-90 (Bankr.W.D.Ky.1998) (refusing to recognize validity of postpetition creation and perfection of mechanic’s hen because creditor had no lien at the time debtor filed for bankruptcy); Water-vliet Paper Co. v. City of Watervliet (In re Shoreham Paper Co.), 117 B.R. 274, 281-83 (Bankr.W.D.Mich.1990) (finding postpe-tition creation and perfection of property tax lien barred by automatic stay because no prepetition interest existed); Equitable Life Assur. Soc’y v. Ballentine Bros. (In re Ballentine Bros.), 86 B.R. 198, 201 (Bankr. D.Neb.1988) (<HOLDING>); North Side Lumber Co. v. Indus. Indem. Co. 
 Holding statements: (A) holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations (B) holding that the automatic stay would be modified so that a credit union could seek payment of postpetition interest from the codebtor (C) holding judgment in violation of automatic stay void (D) holding that creditors failure to voluntarily turn over property lawfully seized prepetition constituted violation of automatic stay (E) holding that creation of a postpetition tax levy based on a prepetition assessment was barred by the automatic stay
Example Output: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations

Example Input: cite Nance in his Rule 104 brief. Our conclusion is buttressed by the original trial court’s use of its discretion in handling the Cyco evidence, the Iowa Supreme Court’s independent review of the issue on appeal, the PCR court’s thorough and well-reasoned discussion of the issue, the district court’s analysis denying habeas relief, and the overwhelming evidence against Pfau. We are confident the trial court did not abuse its discretion in allowing the limited evidence abou *4 (Iowa Ct.App. Nov.16, 2001) (unpublished) (concluding “evidence of a victim’s gang membership is not inherently prejudicial” in a “case where no evidence was introduced regarding the defendant’s membership in a gang”); State v. Allen, No. 98-2012, 2000 WL 767686, at *2 (Iowa Ct.App. June 14, 2000) (unpublished) (<HOLDING>). Instead, Nance announced that “evidence of 
 Holding statements: (A) holding that trial court did not abuse its discretion by admitting police reports in civil case under publicrecords exception (B) holding trial court did not abuse its discretion in its admitting extraneous evidence to rebut a defensive theory (C) holding the trial court did not abuse its discretion by admitting gangrelated evidence (D) holding trial court did not abuse its discretion in admitting highly probative and relevant evidence of other crimes (E) holding juvenile court did not abuse its discretion in admitting expert testimony
Example Output:
holding that trial court did not abuse its discretion by admitting police reports in civil case under publicrecords exception