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.

this Opinion. Accordingly, it is ORDERED that the Trustee’s Objection to the Debtor’s Claim of exemption in her Toledo, Ohio house, pursuant to 11 U.S.C. § 522(d)(1), be, and is hereby, SUSTAINED. It is FURTHER ORDERED that the Trustee’s Objection to the Debtor’s claim of exemption in past due rents, pursuant to 11 U.S.C. § 522(d)(5), be, and is hereby, DISMISSED without prejudice. 1 . As a resident of Michigan, the Debtor along with her bankruptcy petition also filed a contemporaneous motion for a change of venue to the Northern District of Ohio, Western Division, which this Court granted. 2 . Pursuant to § 522(b), a debtor's right to claim an exemption in bankruptcy is determined by the state in which the debtor is domiciled. See In re Vaughan, 188 B.R. 234, 237 (Bankr.E.D.K.y.1995) (<HOLDING>). Some states like Michigan permit their 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that the terms residence and domicile are not the same thing but that a debtor may only claim an exemption in property where he is domiciled (C) holding that a bankruptcy debtor may claim the homestead exemption for real property transferred to a selfsettled revocable trust even though the settlor and the beneficiary as well as the bankruptcy debtor were the same person (D) holding that the objector must not only show that the facts do not support the exemption but must also prove that the debtor knowingly deceived the trustee and the creditors at the time the exemption was made (E) holding despite contrary authority that husband debtor with a mere possessoiy interest was not entitled to claim a homestead exemption and stating it is a fundamental tenet of the law of exemptions that the debtor must have an ownership interest in the property before an exemption may be claimed a long line of illinois cases has required that a debtor have title or some ownership interest in property in order to claim a homestead exemption other courts deciding the issue under the federal exemption scheme have held that the key word is interest and that an interest in real property up to a specified amount implies a monetary interest more than just one spouses right to reside with the other
holding that spouse could not claim exemption in property that was only property of other spouses estate

n. 7, 713 P.2d at 960 n. 7 (1986) (“Counsel has no right to cast upon the court the burden of searching through a voluminous record to find the ground of an objection. It is counsel’s duty to cite accurately the portions of the record supporting counsel’s position.” (Internal citation omitted.)); Hoang, 93 Hawaii at 336, 3 P.3d at 602 (2000) (“Because the factual basis of [appellant’s] alleged point of error is not part of the record on appeal, this court has no basis upon which to rule on the merits of his claim.” (Citation omitted.)) Even if Appellants’ allegations of fraudulent inducement are taken at face value, they fall short of “clear and convincing” evidence of fraudulent inducement. Honolulu Federal Savings & Loan Ass’n v. Murphy, 7 Haw. App. 196, 202, 753 P.2d 807, 812 (1988) (<HOLDING>). At a more fundamental level, they do not 
 Holding statements: (A) holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof (B) holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied (C) holding that the standard of proving fraudulent inducement with respect to written contracts is extremely high and a written contract will be cancelled only in a clear ease of fraud supported by clear and convincing evidence citations omitted (D) holding that fraud on the court must be supported by clear unequivocal and convincing evidence (E) holding clear and convincing standard to prove fraud or fraudulent intent and preponderance of the evidence to prove other elements under  727
holding that a finding of fraud may be reversed only for clear error but that the finding must be judged in view of the clear and convincing burden of proof

in that country because of the alien’s race, religion, nationality, membership in a particular social group, or political opinion.” 8 U.S.C. § 1231(b)(3)(A). Withholding of removal requires a “clear probability” of persecution. Toussaint v. Attorney Gen., 455 F.3d 409, 413 (3d Cir.2006). The petitioner has the burden of demonstrating that persecution will be “committed either by the government or by forces that the government is either unable or unwilling to control.” Mulanga v. Ashcroft, 349 F.3d 123, 132 (3d Cir.2003). Where violence is “primarily wrought by fellow citizens and not the result of governmental action or acquiescence,” there is no pattern of persecution sufficient to support the granting of withholding of removal. Lie v. Ashcroft, 396 F.3d 530, 537-38 (3d Cir.2005) (<HOLDING>). Similarly, to obtain relief under the CAT, a 
 Holding statements: (A) holding that petitioners who apply for withholding of removal must establish that a statutorily protected ground was a reason for their persecution (B) holding that petitioner an ethnic chinese christian from indonesia did not establish a wellfounded fear of future persecution in indonesia because she failed to demonstrate that she would be individually targeted for persecution and country reports indicate that religious discrimination and harassment of ethnic chinese have declined in previous years (C) holding that absent solid support in the record for the petitioners assertion that he would be subjected to persecution his fear was speculative at best (D) holding that evidence of antichinese violence in indonesia did not support the petitioners claim that persecution would result from removal (E) holding that the denial of petitioners appeal to the bia would have put a reasonable person in the petitioners position on notice that something was wrong with his attorneys preparation for the removal hearing

holding that petitioners who apply for withholding of removal must establish that a statutorily protected ground was a reason for their persecution