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: Corrupt Organizations Act (“RICO”) because Erickson failed to allege specific facts showing a pattern of racketeering activity. See Sanford v. Member-Works, Inc., 625 F.3d 550, 557-58 (9th Cir.2010) (discussing elements of a.RICO claim and particularity requirements of Fed.R.Civ.P. 9(b)). The district court properly dismissed Erickson’s claims under the Real Estate Settlement and Procedures Act (“RES-PA”) and the Truth in Lending Act (“TILA”) as time-barred because Erickson filed his action more than three years after the alleged violations. See 12 U.S.C. § 2614 (prescribing at most a three-year statute of limitations for violations of RES-PA); 15 U.S.C. § 1640(e) (an action for damages under TILA must be brought within one year of the alleged violation); see also King, 784 F.2d at 915 (<HOLDING>). However, after the district court dismissed 
 Holding statements: (A) holding fiveyear limitation period in 28 usc  2462 runs from date of predicate violation not from date of administrative assessment of sanction (B) holding limitations period for filing petition for postconviction relief runs from date of final judgment not from date of subsequent order revoking appeal bond (C) holding that oneyear period runs from the discovery of the transfer (D) holding that the limitations period in section 1640e runs from the date of consummation of the transaction (E) holding  under section 1144s predecessor statute  that the 180day period runs from the date of the confirmation order even if the fraud is not discovered in the 180day period
Example Output: holding fiveyear limitation period in 28 usc  2462 runs from date of predicate violation not from date of administrative assessment of sanction

Example Input: It is axiomatic, however, that states act through their officials and agencies. Thus, under Will, those state agencies and other political subdivisions which carry out the state’s business and have immunity from lawsuits under the Eleventh Amendment constitute “arms of the state.” Pursuant to Will, such entities would not be considered persons under § 1983. Those political subdivisions which are not provided immunity under the Eleventh Amendment, do not rise to the level of “arms of the state” and would, under Will, be considered to be persons for the purposes of § 1983. See Barket, Levy & Fine v. St. Louis Thermal Energy Corp., 948 F.2d 1084, 1086-88 (8th Cir.1991) (bi-state agency is a “person” under § 1983); Magula v. Broward Gen. Medical Ctr., 742 F.Supp. 645, 649 (S.D.Fla.1990) (<HOLDING>). Since the Will decision was handed down, a 
 Holding statements: (A) holding that a county is not an arm of the state for purposes of the eleventh amendment (B) holding that an ohio school district is more like a county or city than it is like an arm of the state and therefore it is not entitled to assert eleventh amendment immunity from suit (C) holding that the anne arundel board of education is an arm of the state for purposes of eleventh amendment immunity (D) holding that the puc is not an arm of the state and rejecting claim of immunity (E) holding that because hospital district is more like a municipality than an arm of the state hospital district did not have eleventh amendment immunity
Example Output: holding that a county is not an arm of the state for purposes of the eleventh amendment

Example Input: doubt” submitted to the jury that convicted him may have been unconstitutional. Moreover, as discussed infra, because trial counsel manifestly intended, at the end of the trial, to defend Mercer based solely on an insanity defense, counsel was reasonably unconcerned about the reasonable doubt instruction as it had no relevance to such defense upon which Mercer as the defendant earned the burden. Indeed, as discussed, Discussion, infra, at 240-43, because trial counsel tactically chose to rely on a concession that Mercer had committed the crimes charged in order to sustain the insanity defense for Mercer, such indifference to the reasonable doubt charge as given by Judge Han-nigan was completely understandable. Because as of the date of Mercer’s trial, t 46, 150 (N.D.N.Y.1996) (<HOLDING>). Nevertheless, insofar as Cage is, for 
 Holding statements: (A) holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel (B) recognizing a constitutional claim for ineffective assistance of counsel (C) holding that defendant may raise claim of ineffective assistance of counsel on direct appeal only if ineffective assistance is conclusive from the record (D) holding that failure to object to admissible evidence was not ineffective assistance of counsel (E) holding no ineffective assistance of appellate counsel claim for failure to raise as basis for appeal of conviction ineffective assistance of trial counsel where basis for the latter claim was inadequate
Example Output:
holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel