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.

[EX Q]: aff'd, 683 So.2d 1042 (Ala.1996), cert. denied, 520 U.S. 1171, 117 S.Ct. 1438, 137 L.Ed.2d 545 (1997), quoting Ex parte Wilson, 571 So.2d 1251, 1261 (Ala.1990). In Brooks v. State, 695 So.2d 176 (Ala.Cr.App.1996), aff'd, 695 So.2d 184 (Ala.), cert. denied, 522 U.S. 893, 118 S.Ct. 233, 139 L.Ed.2d 164 (1997), this Court stated: “[A] prosecutor has the right to indicate to the jury those parts of the evidence or testimony presented by the State that the defense has failed to contradict; that process is not an infringement of the defendant’s Fifth Amendment privilege against self-incrimination. Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App.1981).” 695 So.2d at 180 (<HOLDING>). “ ‘ “A prosecutor’s statement that the 
 Holding statements: (A) holding that it was permissible for prosecutor to comment on the general failure of the defense to produce any evidence (B) recognizing the right of a defendant to comment upon the failure of the state to produce evidence (C) holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendants innocence was not a comment on the defendants failure to testify (D) holding the prosecutors statements were not an inappropriate comment on the defendants failure to testify but rather a comment on the defendants failure to present convincing evidence to support his defense (E) holding a prosecutor may not comment on a defendants silence
[EX A]: holding that it was permissible for prosecutor to comment on the general failure of the defense to produce any evidence

[EX Q]: issue in question.” Bradley Ventures, Inc. v. Farm Bureau Mut. Ins. Co. of Ark., 371 Ark. 229, 264 S.W.3d 485, 490 (2007). UAMS maintains that collateral estoppel applies to Dodson I and II, barring both of Dodson’s pending claims, but our discussion is considerably narrower. First, I would set aside Dodson I because I am uncertain that the court’s relevant finding was “essential to the judgment.” Powell, 289 S.W.3d at 444. Second, I would set aside Count II, which is Dodson’s impliedeontract claim. Importantly, Count II is premised on UAMS’s conduct after Dodson II, i.e., sending Dodson bills for the embryo storage fees, and therefore cannot be precluded by the earlier chancery court decision. See Ripplin Shoals Land Co. v. U.S. Army Corps of Eng’rs, 440 F.3d 1038, 1044 (8th Cir.2006) (<HOLDING>); cf. id. at 1042 (“[R]es judicata does not 
 Holding statements: (A) holding that an assignment does not modify the terms of the underlying contract (B) recognizing that a final judgment may provide for a particular standard upon which to modify a final judgment (C) holding that a prior judgment regarding a permit to modify an existing bridge does not preclude a plaintiff from challenging a decision on a new application describing and a different bridge design (D) holding that district court did not abuse its discretion in refusing to permit a design defect products liability expert to submit an untimely addendum stating a new claim of failure to warn after defense expert refuted the basis of original design defect opinion (E) holding untimeliness of motion to modify medical insurance payment did not preclude motion to modify maintenance
[EX A]: holding that an assignment does not modify the terms of the underlying contract

[EX Q]: be clear that our assertion that there are some burdens so minor that they do not amount to a violation should not be taken as an invitation to impose a substantial burden test by indirection. But cf. Ford, 352 F.3d at 591 (describing prison officials' argument that denying an inmate one religious feast meal “is not a 'substantial burden'-or, in other words, is a 'de minimis burden’-on [plaintiff's] religious exercise”). 7 .See also, e.g., DeHart, 227 F.3d 47 (finding that Buddhist plaintiff whose request for a vegetarian diet was denied because vegetarianism was not an absolute requirement of Buddhism had stated a free exercise claim, and remanding for further factual findings regarding the existence of countervailing pe-nological interests); Love v. Reed, 216 F.3d 682 (8th Cir.2000) (<HOLDING>); Makin v. Colo. Dep’t of Corr., 183 F.3d 1205 
 Holding statements: (A) holding that  relatively shortterm and sporadic  intrusions on an inmates prayer activities did not constitute a substantial burden on inmates free exercise of his religion (B) holding that prisons policy of supplying orthodox jewish inmates with one frozen kosher dinner supplemented with nonkosher vegetarian or nonpork meals violated prisoners free exercise rights (C) holding that prison officials failure to accommodate inmates meal requirements during ramadan violated his free exercise rights (D) holding that denial of inmates request for bread and peanut butter so that he could prepare his sunday meals in his cell on saturday  thereby avoiding preparing food or benefitting from the preparation of food by others on the sabbath  violated prisoners free exercise rights (E) holding scheduling employee for later shift on sunday so he could attend church did not eliminate conflict with his second religious practice of not working at all on sunday his sabbath
[EX A]:
holding that  relatively shortterm and sporadic  intrusions on an inmates prayer activities did not constitute a substantial burden on inmates free exercise of his religion