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: of the evidence. Hicks, 509 U.S. at 511, 113 S.Ct. at 2749. In interpreting Hicks, supra, the Second Circuit has stated definitively as follows: [Defendant] misreads the Supreme Court’s statement in Hicks that once a defendant produces evidence of a legitimate, nondiscriminatory reason for his or her action, the plaintiff must then establish that the defendant’s actions were intentionally discriminatory. [Defendant] takes this statement as requiring the plaintiff to adduce additional evidence after the defendant’s production — evidence beyond that presented in the plaintiffs prima facie case. Justice Scalia took pains to preclude such an interpretation of the Court’s decision when he observed that, upon rejection of the defendant’s proffered reasons for its action , 142 (2d Cir.1993) (<HOLDING>), cert. denied, — U.S. -, 114 S.Ct. 1189, 127 
 Holding statements: (A) holding the plaintiff satisfies the burden of a prima facie case by a preponderance of the evidence (B) holding that former employer met its burden of proof that ubc exception applied (C) holding that the burden of proof is on the claimant (D) holding plaintiffs ultimate burden of proof can be met by combining proof submitted in its prima facie case with evidence that defendants proffered reasons for its acts were false (E) recognizing that a plaintiffs burden in establishing a prima facie case is not onerous
Example Output: holding the plaintiff satisfies the burden of a prima facie case by a preponderance of the evidence

Example Input: [u]nder [28 U.S.C.] § 2254(d)(l)’s ‘unreasonable application’ clause, ... a federal habeas [corpus] court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather, that application must also be unreasonable. Id. at 411, 120 S.Ct. 1495. Applying these standards to the present case, the court’s inquiry must be whether the uit Court of Appeals case for the proposition that the application of a statute prohibiting felons from possessing firearms does not violate the ex post facto clause because it is a protective measure and does not impose any new or different punishment. See United States v. O’Neal (“O’Neal”), 180 F.3d 115, 124-25 (4th Cir.1999) (<HOLDING>) (criticizing Davis). Additionally, the 
 Holding statements: (A) holding that state statutory bans against employment of convicted felons in certain jobs did not impose punishment under ex post facto clause (B) holding that revocation of medical license does not violate the ex post facto clause (C) holding north carolina felony firearms act did not violate the ex post facto clause because it was a measured public safety provision and its applicability to previously convicted felons was eminently reasonable (D) holding that the ex post facto clause did not apply because the civil contempt citation was not punitive (E) holding that the alaska sex offender registration act did not violate the ex post facto clause
Example Output: holding that state statutory bans against employment of convicted felons in certain jobs did not impose punishment under ex post facto clause

Example Input: (stating that probable cause to arrest exists when officer has “reasonable ground for belief of guilt that was particularized with respect to the person to be ... seized”) (internal quotation marks omitted). Accordingly, the district court properly denied the motion to suppress, and we affirm the court’s judgment. We deny Holland’s motion to file a pro se supplemental brief and dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED. * The Government argues that, in determining whether a seizure occurred, we should apply the "force or submission” standard set forth in California v. Hodari D., 499 U.S. 621, 626, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991) (<HOLDING>). The Govern ment contends that, because 
 Holding statements: (A) holding iowa common law touching assault met use of physical force required for enhancement under 18 usc  922g9 be cause any physical contact by necessity requires physical force to complete (B) holding that  2241a1 requires actual use of force meaning use of such physical force as is sufficient to overcome restrain or injure a person (C) holding that an arrest requires either physical force  or where that is absent submission to the assertion of authority (D) holding that an arrest may involve either 1 taking the alleged violator into exlended physical custody or 2 issuing the individual a citation and noting that when we use the word arrest in this opinion we refer to physical arrest (E) holding that emotional distress requires a showing of either physical symptoms or mental illness
Example Output:
holding iowa common law touching assault met use of physical force required for enhancement under 18 usc  922g9 be cause any physical contact by necessity requires physical force to complete