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.
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Question: court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts

Answer: holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort


Question: to the section 924(c) jury instruction, we review it for plain error. See, e.g., United States v. Webster, 84 F.3d 1056, 1066 (8th Cir.1996). Although the pre-Bailey instruction was given to the jury (because Bailey had no rovide a defendant, upon their motion, any statement or report made by a government witness that relates to the subject matter of the direct testimony of that witness. 18 U.S.C. § 3500. The government need not provide the statement, however, until after the witness testifies on direct examination. 18 U.S.C. § 3500(a). 6 . The district court’s ruling was essentially a discovery matter, which we review for an abuse of discretion. See, e.g., United States v. Byrne, 83 F.3d 984, 990 (8th Cir.1996); see also United States v. Phillips, 854 F.2d 273, 278 (7th Cir.1988) (<HOLDING>). But see United States v. Monroe, 943 F.2d 
 Holding statements: (A) holding that the district court did not abuse its discretion in concluding that the fbi informants file contained no brady material not already provided to the defendant in a summary (B) holding that the alleged brady material was merely cumulative to the significant impeachment that already occurred during trial so there was no prejudice for a brady violation (C) holding that an fbi agents rough notes of an interview of the defendant were not brady material because there was no independent showing that they contained evidence that was material to the defendants guilt or innocence (D) holding a trial court did not abuse its discretion by failing to require disclosure of an informants name (E) holding the district court did not abuse its discretion by applying local rules that excluded some of the material facts offered in opposition to a motion for summary judgment

Answer: holding that the alleged brady material was merely cumulative to the significant impeachment that already occurred during trial so there was no prejudice for a brady violation


Question: sentence of life imprisonment that Hanson was told he could receive. See United States v. Schuh, 289 F.3d 968, 974 (7th Cir.2002). Although the court did not tell Hanson that he had the right to plead not guilty, see Fed. R.Crim.P. 11(c)(3), this error was harmless because Hanson was aware of his right to plead not guilty; he originally had pleaded not guilty to both counts of the indictment and then changed his plea to guilty, see Knox, 287 F.3d at 670. Counsel also states that the court did not inform Hanson that he was giving up the right to confront witnesses against him at trial. See Fed.R.Crim.P. 11(c)(3). Because the court informed Hanson that “at a trial [he] would have the right to cross-examine witnesses against” him, we agree with counsel that this again would be har r.2002) (<HOLDING>). Furthermore, there is no time period 
 Holding statements: (A) holding that burglary is violent felony (B) holding that all escapes qualify as violent felonies (C) holding that  2255 movant claiming his prior conviction for assault was not a violent felony did not qualify for actual innocence exception (D) holding that when an inmate escapes from a guarded facility he acts with purposeful violent and aggressive behavior and creates a substantial risk of violent confrontation (E) holding a burglary must be of a building or structure in order to qualify as a violent felony for acca purposes

Answer:
holding that burglary is violent felony