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.
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Question: § 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the § 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA’s one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this § 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, — U.S. -, 121 S.Ct. 78, 148 
 Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted

Answer: holding that issues not raised before the district court cannot be raised for the first time before this court


Question: and sold it to nonre-latives. We conclude that the evidence is not sufficient to rebut the presumption that the property is marital. The form of the transaction, while not dispositive, is compelling in the instant case because of Klem’s knowledge of, and experience with, joint tenancies. Klem was fully aware of how joint tenancies operated. As the husband of Hazel, he became the sole owner of Hazel’s family property as a surviving joint tenant, a fact he acknowledged during his deposition. Subsequent to his sole ownership of the property, he knowingly deeded the property to Larry and Colleen as joint tenants. In so doing, he gave both parties an interest in the property. See Melina v. Melina, 411 N.W.2d 204, 207 (Minn.App.1987); Erdahl v. Erdahl, 384 N.W.2d 566, 567 (Minn.App.1986) (<HOLDING>). Finally, also indicative of the donor’s 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that devise of real estate to one spouse was nonmarital and noting that had testator intended such property to be devised as marital property he could have designated appellant as a joint tenant (C) holding money received from inheritance as nonmarital property presumptively became marital property when placed in joint account under arkansas law (D) holding that transferring joint property into one partys name for estate planning purposes does not convert marital property into nonmarital property (E) holding that circuit court erred in failing to consider that marital property in the form of marital earnings was used to pay debt against nonmarital property

Answer: holding that spouse could not claim exemption in property that was only property of other spouses estate


Question: is fraudulent include but are not limited to the timing of the union, whether the couple intends to live together as husband and wife, and whether the couple entered the marriage in good faith. In re Grand Jury Proceedings (84-5), 111 F.2d 508, 509 (9th Cir.1985) (stating mere suspicious timing of union does not alone support finding of sham marriage, where individuals had live-in relationship for some time before subpoena was served on one individual to testify against other individual before grand jury). In this context, when enough facts show the marriage was fraudulent, the spousal testimony privilege cannot be invoked; and a court can compel one spouse to testify against the defendant other spouse in a criminal proceeding. United States v. Mathis, 559 F.2d 294, 298 (5th Cir.1977) (<HOLDING>). The second approach to the spousal testimony 
 Holding statements: (A) holding that right to testify not denied where inter alia defendant made no objection to his attorneys statements that defendant would not testify and made no request to testify (B) holding trial court erred in finding purported wife unavailable to testify and admitting her sworn prior statements in lieu of her live testimony where record did not support courts ruling in light of its own finding that remarriage of wife and defendant was fraudulent and wife did not refuse to testify if claim of privilege was denied (C) holding that trial court did not err in finding that wife was at least somewhat capable of supporting herself where evidence of wifes depression and other mental health problems was uncontested but where other evidence showed that these conditions did not totally bind her to the family home and that wife had been financially successful in the past (D) holding that because the wife failed to present any evidence as to the legal services performed in the trial court the wife was not entitled to a second hearing to establish attorneys fees (E) holding a wife liable for necessary medical expenses incurred by her husband under the doctrine even though the wife did not sign as a guarantor and did not request that her husband be admitted nor anticipate that her husband would be admitted

Answer:
holding that right to testify not denied where inter alia defendant made no objection to his attorneys statements that defendant would not testify and made no request to testify