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.

because of [the dealer’s] precarious financial condition .... ... [W]e decline to hold BMW/NA negligent and liable for damages since it could not reasonably have anticipated the crimes committed by [the dealer’s] principal, Eichler. Although BMW/NA may have been aware of [the dealer’s] shaky financial condition, that knowledge alone gave BMW/NA no cause reasonably to anticipate that Eichler would either engage in any criminal activity or that he would abscond with customer funds. In fact, no amount of supervision by BMW/NA would have enabled it to foresee Eichler’s thievery. Id. In other cases involving the franchisors of automobile dealerships, the courts have reached similar results. See Colson v. Maghami, No. CV 08-2150-PHX-MHM, 2010 WL 2744682, at *9-10 (D.Ariz. July 9, 2010) (<HOLDING>); DaimlerChrysler Motors Co., LLC v. Clemente, 
 Holding statements: (A) holding that owners and officers of automobile dealership who were neither consumers nor competitors in automobile market lacked standing to bring antitrust action against automobile manufacturer (B) holding that a franchisor had no duty to supervise its automobile dealership or to warn a customer of the dealership who paid a substantial deposit for a limited edition lamborghini reventon and who did not receive either the car or the return of his deposit (C) holding that an automobile dealership had no duty to prevent the misconduct of the executives of another company who misappropriated company funds to make the purchase of several automobiles from the dealership (D) holding that where no evidence was designated to show that a car buyer knew that a sale violated the rights of the dealership that owned the car the buyers were buyers in the ordinary course of business for purposes of indcode  26112019 (E) holding that a car dealership could be held vicariously liable for the intentional tort of its employee who shot out the tires of the plaintiffs truck during a repossession attempt
holding that owners and officers of automobile dealership who were neither consumers nor competitors in automobile market lacked standing to bring antitrust action against automobile manufacturer

this Opinion. Accordingly, it is ORDERED that the Trustee’s Objection to the Debtor’s Claim of exemption in her Toledo, Ohio house, pursuant to 11 U.S.C. § 522(d)(1), be, and is hereby, SUSTAINED. It is FURTHER ORDERED that the Trustee’s Objection to the Debtor’s claim of exemption in past due rents, pursuant to 11 U.S.C. § 522(d)(5), be, and is hereby, DISMISSED without prejudice. 1 . As a resident of Michigan, the Debtor along with her bankruptcy petition also filed a contemporaneous motion for a change of venue to the Northern District of Ohio, Western Division, which this Court granted. 2 . Pursuant to § 522(b), a debtor's right to claim an exemption in bankruptcy is determined by the state in which the debtor is domiciled. See In re Vaughan, 188 B.R. 234, 237 (Bankr.E.D.K.y.1995) (<HOLDING>). Some states like Michigan permit their 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that the terms residence and domicile are not the same thing but that a debtor may only claim an exemption in property where he is domiciled (C) holding that a bankruptcy debtor may claim the homestead exemption for real property transferred to a selfsettled revocable trust even though the settlor and the beneficiary as well as the bankruptcy debtor were the same person (D) holding that the objector must not only show that the facts do not support the exemption but must also prove that the debtor knowingly deceived the trustee and the creditors at the time the exemption was made (E) holding despite contrary authority that husband debtor with a mere possessoiy interest was not entitled to claim a homestead exemption and stating it is a fundamental tenet of the law of exemptions that the debtor must have an ownership interest in the property before an exemption may be claimed a long line of illinois cases has required that a debtor have title or some ownership interest in property in order to claim a homestead exemption other courts deciding the issue under the federal exemption scheme have held that the key word is interest and that an interest in real property up to a specified amount implies a monetary interest more than just one spouses right to reside with the other
holding that spouse could not claim exemption in property that was only property of other spouses estate

to crimes with even greater precision than criminal legislation. See Baja-kajian, 524 U.S. at-, 118 S.Ct. at 2044 (Kennedy, J., dissenting) (noting that the purpose of the sentencing guidelines “is to select punishments with precise proportion”). Therefore, although we retain a duty under the Eighth Amendment independently to examine fines for excessiveness, a defendant would need to present a very compelling argument to persuade us to substitute our judgment for that of the United States Sentencing Commission. Thus, in a forfeiture action, if the value of the property forfeited is within or near the permissible range of fines under the sentencing guidelines, the forfeiture almost certainly is not excessive. See United States v. 427 & 429 Hall St, 74 F.3d 1165, 1172-73 (11th Cir.1996) (<HOLDING>); see also Bajakajian, 524 U.S. at-, 118 S.Ct. 
 Holding statements: (A) holding that forfeiture of property valued at 150000 was excessive where the maximum statutory fine was 20000 (B) holding that forfeiture of property valued at 65000 was not excessive where the maximum fine under the sentencing guidelines was 40000 (C) holding statutory maximum for prior conviction is the potential maximum sentence defined by the applicable state criminal statute not the maximum sentence which could have been imposed against the particular defendant  according to the states sentencing guidelines (D) holding that forfeiture of 357144 in currency was excessive where the maximum statutory fine was 250000 and the maximum fine under the sentencing guidelines was 5000 (E) holding defendant sentenced to term equal to maximum guidelines sentence under improperly calculated sentencing guidelines scoresheet was not entitled to be resentenced because defendant was habitualized such that sentencing guidelines score sheet was irrelevant and the sentence imposed was not illegal

holding that forfeiture of property valued at 150000 was excessive where the maximum statutory fine was 20000