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.

in which this Court's authority to review criminal convictions was greatly circumscribed.” Cotton, 535 U.S. at 629, 122 S.Ct. 1781. It could examine constitutional errors in a criminal trial only on a writ of habeas corpus, and only then if it deemed the error "jurisdictional.” Id. (internal quotation marks omitted). "The Court’s desire to correct obvious constitutional violations led to a 'somewhat expansive notion of jurisdiction.Id. (quoting Custis v. United States, 511 U.S. 485, 494, 114 S.Ct. 1732, 128 L.Ed.2d 517 (1994)) (internal quotation marks omitted). 25 . A charging instrument may be so deficient that a court does not have jurisdiction over the case; for instance, if the charging document was never filed. See State v. Kaulia, 128 Hawai'i 479, 491, 291 P.3d 377, 389 (2013) (<HOLDING>). Without deciding the matter, a charge that 
 Holding statements: (A) holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted (B) holding that an action brought against the state officials in their official capacities was not properly removed to federal court because the district court lacked jurisdiction (C) holding that the appellate court had jurisdiction to hear the interlocutory appeal on a restraining order and the district court retained jurisdiction to proceed with the trial (D) holding that the district court lacked jurisdiction to review state disciplinary proceedings against attorney (E) holding that because the state failed to properly file the complaint the district court lacked jurisdiction to proceed to trial
holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted

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
holding that an assignment does not modify the terms of the underlying contract

2074, 48 L.Ed.2d 684 (1976)); see also Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 547 n. 13, 105 S.Ct. 1487, 84 L.Ed.2d 494 (1985) (noting that “the failure to allege that the reasons for the dismissal were published dooms” plaintiffs liberty interest claim); Dickeson v. Quarberg, 844 F.2d 1435, 1440 (10th Cir.1988) (“A liberty interest is not violated when one is discharged without public disclosure of the reasons for the discharge.”). Thus, speculative rumors circulating in the community as a result of defendants’ failure to publish do not establish a deprivation of a liberty interest. While the injury to reputation asserted by the plaintiff may be actionable under state tort law , it falls far short of a constitutional violation. See Paul, 424 U.S. at 697-99, 96 S.Ct. 1155 (<HOLDING>). Accordingly, we affirm the district court’s 
 Holding statements: (A) holding that a defamation claim is a personal injury tort claim (B) holding that merely declining to rehire a person did not constitute defamation for deprivation of liberty interest purposes absent any charges against the good name or reputation of that person (C) holding that harassment or discrimination does not rise to the level of persecution under the ina unless it is accompanied by physical punishment infliction of harm or significant deprivation of liberty (D) holding that defamation standing alone is not sufficient to establish a claim for deprivation of a liberty interest citations omitted (E) holding that conduct actionable as state claim for defamation does not rise to level of liberty deprivation simply because government officials are involved

holding that a defamation claim is a personal injury tort claim