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.

to landslide, even though earth movement was the most immediate cause). We therefore conclude that this is a case of multiple causation. B. We must now determine whether the deterioration or the fungicide manufacturers’ failure to warn is the “proximate efficient cause” of the damage to Berry’s irrigation pipes. In Sabella, the California Supreme Court defined “proximate efficient cause” both as “the one that sets others in motion” and as “the predominating or moving efficient cause.” Sabella, 27 Cal.Rptr. at 695, 377 P.2d at 895; see Garvey, 257 Cal.Rptr. at 296, 770 P.2d at 708 (“Sabella defined ‘efficient proximate cause’ alternatively as the ‘one that sets others in motion’ and as ‘the predominating or moving efficient cause.’”) (citations omitted); Howell, 267 Cal.Rptr. at 716 (<HOLDING>); Brian Chuchua’s Jeep, 13 Cal.Rptr.2d at 445 
 Holding statements: (A) recognizing the existence of purely jurisdictional elements (B) recognizing existence of two tests (C) recognizing first two exceptions (D) recognizing that the existence of an agency relationship is ordinarily a question of fact (E) recognizing the existence of the special relationship
recognizing the existence of purely jurisdictional elements

until they were “in close proximity.” Lowe, 2014 WL 99452, at *3; see also Westport Ins. Corp. v. Bayer, 284 F.3d 489, 498 (3d Cir.2002) (according plain meaning to the district court’s choice of language in affirming its “implicit” findings of fact). These findings control because they are not clearly erroneous. Rather, they are suppo a- suspect takes action that clearly indicates that he “does not yield” to the officers’ show of authority. Hodari D., 499 U.S. at 626, 111 S.Ct. 1547. Action— not passivity — has been the touchstone of our an h Cir.2010) (noting that, “for a person who is moving, to ‘yield’ most sensibly means to stop”), or when a suspect makes suspicious motions consistent with reaching for a weapon, see United States v. Johnson, 212 F.3d 1313, 1316-17 (D.C.Cir.2000) (<HOLDING>). Unlike the suspects in those cases, Lowe 
 Holding statements: (A) holding that i have a gun is sufficient to justify the sentencing enhancement because it merely requires a teller to make the reasonable inference that a robber would use the gun he claimed to have if he did not receive the money he demanded (B) holding that a suspect did not submit to a show of authority when he made continued furtive  gestures including shoving down motions that were suggestive of hiding or retrieving a gun (C) holding that a suspect who continued walking when approached by a police officer did not submit until physically restrained by the officer (D) holding that evidence of appellants prior gun possession was admissible in a homicide prosecution to show malice and intent possession of a gun without more is not wrongful conduct (E) holding direct testimony tying a defendant to a gun was not required when the gun was found in the defendants truck and when the defendant had both ammunition for the gun and a rack in which it could have been kept
holding that i have a gun is sufficient to justify the sentencing enhancement because it merely requires a teller to make the reasonable inference that a robber would use the gun he claimed to have if he did not receive the money he demanded

Lewis v. Woods, 848 F.2d 649, 652 (5th Cir.1988); and Simmons v. McElveen, 846 F.2d 337, 339 (5th Cir.1988). 169 . See City of Canton v. Harris, 489 U.S. 378, 389, 109 S.Ct. 1197, 1205, 103 L.Ed.2d 412 (1989); Colle v. Brazos County, 981 F.2d at 245-46; Rhyne v. Henderson County, 973 F.2d at 392; and Benavides v. County of Wilson, 955 F.2d at 972-73. 170 . Id. 171 . See Collins v. City of Harker Heights, Texas, 916 F.2d at 286. 172 . See Valley v. Rapides Parish School Board, 118 F.3d 1047, 1051 n. 1 (5th Cir.1997); and Chrissy F. by Medley v. Mississippi Department of Public Welfare, 925 F.2d 844, 849 (5th Cir.1991). 173 . See DSC Communications v. Next Level Communications, 107 F.3d 322, 328 (5th Cir.1997); and Wallace v. Texas Tech University, 80 F.3d 1042, 1047 n. 3 (5th Cir.1996), (<HOLDING>). 174 . See Wallace v. Texas Tech University, 
 Holding statements: (A) holding that the eleventh amendment precludes an award of injunctive or declaratory relief that is not prospective in nature (B) holding that injunctive relief was unwarranted when the jurys award already included prospective relief (C) holding that eleventh amendment does not bar federal suit against state official for prospective injunctive relief (D) holding that a class of juveniles had standing to seek injunctive relief in federal court against future interrogations by a police squad because of the strong likelihood that the challenged interrogation methods would be used again (E) holding that prospective injunctive relief is appropriate in a federal civil rights action only if a reasonable likelihood exists the plaintiff will again be subjected to the unconstitutional actions

holding that the eleventh amendment precludes an award of injunctive or declaratory relief that is not prospective in nature