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: two separate legal insufficiency claims. When the party without the burden of proof suffers an unfavorable finding, the challenge is one of “no evidence to support the finding.” See Creative Manufacturing, Inc. v. Unik, 726 S.W.2d 207, 210 (Tex.App.-Fort Worth 1987, writ ref d n.r.e.). Where the party having the burden of proof suffers an unfavorable finding (failure to find), the proper complaint is that the fact was established as “a matter of law.” See Sterner v. Marathon Oil Company, 767 S.W.2d 686, 690 (Tex.1989). Here, Tech filed a verified special denial that it received timely notice. Consequently, Lucero had the burden to plead and secure a finding on notice. See Texas Tech University Health Sciences Center v. Apodaca, 876 S.W.2d 402, 410-11 (Tex.App.-El Paso 1994, writ denied)(<HOLDING>); see also Harrison v. Texas Department of 
 Holding statements: (A) holding that due process rights were not violated when alien claimed a lack of actual notice but his attorney received notice (B) holding that the government need not prove actual notice to the prisoner (C) holding that due process is satisfied where notice is mailed to the wrong address if the appellant received actual notice (D) holding that where the governmental unit filed a verified special denial that it received timely actual notice the plaintiff had the burden to prove and secure a finding on actual notice at trial (E) holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice
Example Output: holding that due process rights were not violated when alien claimed a lack of actual notice but his attorney received notice

Example Input: in the record of any possible medical treatment that Monroe County or the individual defendants could have provided to save the life of the Decedent. Phillips argues in her brief that it is not necessary for her to prove chemotherapy would have saved the Decedent’s life. First, she refers to the fright and anxiety both she and the Decedent suffered because of the delay in chemotherapy. In this regard, Phillips confuses the causation issue. In a survival action, damages for the Decedent’s physical suffering and mental anxiety as a result of the alleged deprivation of medical care would have been appropriate. In a wrongful death context, however, no damages are available until the plaintiff has cleared the causation hurdle. See Wilks v. Am. Tobacco Co., 680 So.2d 839, 842 (Miss.1996) (<HOLDING>). Second, Phillips suggests that she need only 
 Holding statements: (A) recognizing cause of action for wrongful death (B) holding that plaintiffs failure to prove decedents death was caused by the wrongful acts of the defendant precludes any recovery of wrongful death damages under mississippis wrongful death statute (C) holding unconstitutional a state wrongful death statute which denied illegitimate children the right to recover for the wrongful death of their mother (D) holding that a failure to include a beneficiary in a wrongful death action is a defect because the wrongful death act restricts plaintiffs to a single action (E) holding that mississippis wrongful death statute creates an independent cause of action
Example Output: recognizing cause of action for wrongful death

Example Input: claim first be classified as “an allowed secured claim” within the meaning of Section 1325(a)(5). Under Nobelman and Zimmer, as discussed above, when a creditor is wholly unsecured after application of Section 506(a), the creditor has only an unsecured claim for purposes of Section 1322(b)(2). The creditor is not the holder of a secured claim, and as such, Section 1325(a)(5), which, by its language applies only to secured claims, does not apply to the wholly unsecured creditor. Hill, when considering this issue, reached this very conclusion. After considering many of the same decisions that this court has considered, and after the same analysis of the statutory text that this court has engaged in, the court found that Section 1325(a)(5) “has no applicability to unsecured claims, whi ) (<HOLDING>); In re Frazier, — B.R. -, 2011 WL 1206198, *6 
 Holding statements: (A) holding that if  506 does not apply to an allowed claim such claim cannot become a secured claim (B) holding that the meaning of allowed secured claim in  506a does not determine the meaning of allowed secured claim in  506d (C) holding that the words allowed secured claim in  506d refer to a claim that is secured by a lien and allowed under  502 (D) holding that if claim is not an allowed secured claim pursuant to section 506a by its terms section 1325a5b is inapplicable (E) holding that where there was no value in the collateral to secure the claim after application of section 506a creditor did not hold a secured claim and therefore lacked basis for asserting rights under 11 usc  1325a5
Example Output:
holding that if  506 does not apply to an allowed claim such claim cannot become a secured claim