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: period under IAD never commenced); Fields v. United States, 698 A.2d 485, 489-90 (D.C. 1997) (rejecting prisoner’s substantial compliance argument and recognizing that court is bound by Fex); State v. Greenwood, 665 N.E.2d 579, 581-82 (Ind. 1996) (requiring strict compliance with IAD procedures and recognizing that procedures are "not mere technicalities”); Pinto v. Warden, C.A. No. 972412, 1999 WL 49378, at *7 (Conn. Super. Jan. 20, 1999) (stating that "[wjhile it is true that earlier decisions of courts were split on when the 180 day period begins, the majority of courts ... have held that the period begins to run once the request is actually received by the appropriate court and prosecutor”); Commonwealth v. Flores, C.A. No. 91-493, 1998 WL 792466, at *3 (Mass. Super. Nov. 6, 1998) (<HOLDING>). 48 . 1993 WL 138993, at *1 (Del. Super. Apr. 
 Holding statements: (A) holding that a pro se prisoner complaint is deemed filed as of the date the prisoner gives the complaint to prison officials to be forwarded to the court (B) holding that an noa filed by a pro se prisoner is deemed filed on the date that the prisoner delivers it to prison authorities for mailing (C) holding that the language of the statute and the courts duty to apply the statute as written requires the court to interpret the statute to apply when the prisoner is sentenced without regard to the institution where the prisoner is incarcerated after the sentencing (D) holding that the iad as construed by fex requires that a prisoner must be tried within 180 days of the date when his request for disposition is actu ally received by the state in which the charges are pending not when the prisoner provides that request to his custodial authorities (E) holding time begins when the prisoner knows  the important facts not when the prisoner recognizes their legal significance
Example Output: holding that a pro se prisoner complaint is deemed filed as of the date the prisoner gives the complaint to prison officials to be forwarded to the court

Example Input: clause could be vitiated based on evidence of fraud “relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs’ allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 (“Fraud ... makes a contract voidable at the instance of the innocent party.”) (quoting 3 Corbin, Contracts, § 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs’ argument conflates their tort 
 Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable
Example Output: holding that a contract made in violation of section 432070 is void rather than voidable

Example Input: Appellants asserted below. See Harper, 138 Fed.Appx. at 132-33 (dismissing Fair Debt Collection Practices Act claims); Figueroa v. Merscorp, Inc., 766 F.Supp.2d 1305, 1316 (S.D.Fla.2011) (dismissing a RICO claim under Rooker-Feldman); Distant v. Bayview Loan Servicing, LLC, No. 09-61460-CIV, 2010 WL 1249129, at *3 (S.D.Fla. Mar. 25, 2010) (unpublished)(“AIthough plead as conspiracy claims ..., Plaintiff is clearly asking this Court to invalidate the state court action by ruling that the state court foreclosure judgment is somehow void. Under the Rooker-Feldman doctrine, ... this Court lacks subject matter jurisdiction, as Plaintiff seeks a de facto appeal of a previously litigated state court matter.”); Simpson v. Putnam Cnty. Nat’l Bank of Carmel, 20 F.Supp.2d 630, 633 (S.D.N.Y.1998) (<HOLDING>); Smith v. Wayne Weinberger, P.C., 994 F.Supp. 
 Holding statements: (A) holding that a party is not entitled to pursue a separate action for deficiency judgment where the foreclosure complaint includes a prayer for a deficiency judgment and the foreclosure court reserves jurisdiction to enter a deficiency judgment (B) holding that after a judgment entry grants a decree of foreclosure and order of sale the foreclosure action cannot be dismissed as the judgment is final (C) holding that a foreclosure judgment was not subject to federal review under rookerfeldman and noting that the fact that plaintiff alleges that the foreclosure judgment was procured by fraud and conspiracy does not change that result (D) holding that a failure to comply with the foreclosure statutes invalidates a foreclosure sale (E) holding that 24 foreclosure was substantial under the facts of that case
Example Output:
holding that a party is not entitled to pursue a separate action for deficiency judgment where the foreclosure complaint includes a prayer for a deficiency judgment and the foreclosure court reserves jurisdiction to enter a deficiency judgment