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: with the general contractor to provide materials and labor. Decina, 258 Mich App at 422. 25 Id. 26 Id. at 423. Although the subcontractors did not contract with the homeowners directly, they were nevertheless at least initially entitled to a construction lien under the CLA. See MCL 570.1107(1) (“Each.. . subcontractor . .. who provides an improvement to real property has a construction lien upon the interest of the owner or lessee who contracted for the improvement to real property .. ..”). 27 H A Smith Lumber & Hardware Co v Decina (On Remand), 265 Mich App 380, 382; 695 NW2d 347 (2005), rev’d 480 Mich 987 (2007). 28 Id. 29 Id. at 384-385. 30 Decina, 480 Mich at 988. 31 id. 32 Decina, 258 Mich App at 424, 431. 33 See MCL 570.1107(1) and (6); see also Vugterveen, 454 Mich at 129 (<HOLDING>). 34 Decina, 480 Mich at 988. 36 MCL 
 Holding statements: (A) recognizing that mcl 57011076 provides a real property owner with a defense to a claim of lien if the owner can show that the sum of payments made pursuant to the specific contract plus the claim of lien exceed the price of the contract (B) holding that the lien bond releases the property from the lien but the lien is then secured by the bond (C) holding that under nebraskas physicians lien statute a physicians lien could not exceed the amount the health care provider agreed to accept for the services rendered to a patient even if the usual and customary charge for such services is greater than that sum because the statute extends such lien only to the amount due or debt of the patient to the hospital (D) holding that the current property owner may not assert a public nuisance claim against the former owner (E) holding a lien is a claim against property  here a surety bond and breach of contract is a claim against a person thus the lien proceeding did not dispose of the breach of contract action
Example Output: holding that the lien bond releases the property from the lien but the lien is then secured by the bond

Example Input: initially stopping the truck for failing to illuminate the rear license plate in violation of Kan. Stat. Ann. § 8-1706(e). See United States v. Hunnicutt, 135 F.3d 1345, 1348 (10th Cir.1998) (“An initial traffic stop is valid under the Fourth Amendment ... if the officer has a reasonable articulable suspicion that a traffic or equipment violation has occurred or is occurring.” (citing United States v. Botero-Ospina, 71 F.3d 783, 787 (10th Cir. 1995) (en banc))). Wilson also does not dispute that the smell of alcohol on VanHouden together with VanHouden’s admission that he had been drinking justified the further detention of the truck and its occupants in order for Deputy Watkins to conduct field sobriety tests on VanHouden. See United States v. Neumann, 183 F.3d 753, 756 (8th Cir.1999) (<HOLDING>); Rogala v. Dist. of Columbia, 161 F.3d 44, 52 
 Holding statements: (A) holding that reasonable suspicion standard applies to routine traffic stops (B) holding that an officer has reasonable suspicion to conduct traffic stop even when his suspicion that a law has been violated is based on a reasonable mistake of law (C) holding that the discovery of 2000 in cash during a traffic stop supported a finding of reasonable suspicion (D) holding that an officers reasonable mistake of law can give rise to the reasonable suspicion necessary to justify a traffic stop under the fourth amendment (E) holding detection of alcohol on a drivers breath during a routine traffic stop gave rise to reasonable suspicion
Example Output: holding that reasonable suspicion standard applies to routine traffic stops

Example Input: v. Coburn, 473 F.3d 650, 659 (6th Cir.2007); Shreve v. Jessamine Cnty. Fiscal Court, 453 F.3d 681, 687 (6th Cir.2006); Smoak v. Hall, 460 F.3d 768, 783-84 (6th Cir.2006)). When applying the Sixth Circuit’s three-part test for the entitlement to qualified immunity, the Court finds that Melendez, Randazzo, nor Dotter satisfy the test. With respect to Defendant Melendez, the Sixth Circuit has specifically noted that “ ‘there undoubtedly is a clearly established legal norm precluding the use of violent physical force against a criminal suspect who already has been subdued and does not present a danger to himself or others.’ ” Meirthew, 417 Fed.Appx. at 499 (quoting Harris v. City of Circleville, 583 F.3d 356, 367 (6th Cir.2009)); see also Phelps v. Coy, 286 F.3d 295, 302 (6th Cir.2002) (<HOLDING>), cert. denied, 537 U.S. 1104, 123 S.Ct. 866, 
 Holding statements: (A) holding that an officer intentionally hitting the plaintiffs head into the top of the police car as the plaintiff was being placed in the police car could be excessive force (B) holding that suspect was not in custody when officer handcuffed him for officer safety while transporting him to police station (C) holding that a police officers tackling of a handcuffed suspect hitting him in the face twice and banging his head on the floor three times was unconstitutional (D) holding that when plaintiff a suspect was shown officers credentials and ordered into a police car and plaintiff decided to run running after and tackling plaintiff was not constitutionally excessive (E) holding that a showup identification was valid even though the suspect was handcuffed
Example Output:
holding that an officer intentionally hitting the plaintiffs head into the top of the police car as the plaintiff was being placed in the police car could be excessive force