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: v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (2007). Kyler Road Home Charles first argues on appeal that the circuit court erred by not awarding him an interest in the home on Kyler Road. Although he acknowledges that Myra had acquired this property prior to the marriage, he asserts that he is entitled to an interest in the home because | ^marital funds were used to reduce the debt on the properly and to make improvements. Our definition of marital properly excludes property acquired before the marriage. Ark.Code Ann. § 9-12-315(b)(1) (Repl.2009). However, we have long held that a non-owning spouse is entitled to some benefit when marital funds have been expended to improve or reduce the debt on the other spouse’s nonmarital property. See Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (1993) (<HOLDING>); Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d 
 Holding statements: (A) holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property (B) holding that assets acquired subsequent to separation are not considered marital property absent evidence that spouse used marital property to obtain them (C) holding that separate property may become marital property if spouse donates it to marital unit with intent at time of donation that property become marital (D) holding that the trial court erred in finding that marital property was the former wifes separate property based on a nonseparation agreement in which the former husband purported to relinquish any interest in the marital 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 an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property


Question: unlawful harm under that public policy may include actions that violate recognized and accepted standards of conduct, such as applicable codes of ethics. The critical question in this case is whether under all of the surrounding circumstances MacDougall’s termination by Weiehert violated that clear mandate of public policy and was in retaliation for either his vote on the municipal parking ban ordinance or his refusal to change the ordinance. At the outset, we recognize that conduct that is directed against constitutionally-protected activity may violate a clear mandate of public policy, even though it may not offend any other statutory or legal standard. Supra at 390, 393, 677 A.2d at 167, 168. Compare Shovelin v. Central New Mexico Elec. Coop., Inc., 115 N.M. 293, 850 P.2d 996 (1993) (<HOLDING>) with Novosel v. Nationwide Ins. Co., 721 F.2d 
 Holding statements: (A) holding that employees retaliatory discharge based on employees election to public office did not violate public policy (B) recognizing public policy limits on employer discretion in discharging employees (C) holding public employees conduct and expression in internal investigation of employees at county prosecutors office to expose potential wrongdoing constituted matter of public concern (D) recognizing retaliatory discharge claim where employer prevented employees exercise of workers compensation rights because of employees intention to file claim (E) holding that the discharge of an employee hospitalized for illness did not violate public policy

Answer: recognizing public policy limits on employer discretion in discharging employees


Question: interest in teaching students the boundaries of socially appropriate behavior.” Id. at 681, 106 S.Ct. 3159. Schools are not prevented by the First Amendment from encouraging the “fundamental values of ‘habits and manners of civility,’ ” id., by “insisting that certain modes of expression are inappropriate and subject to sanctions.” Id. at 683, 106 S.Ct. 3159. And “[t]he determination of what manner of speech ... is inappropriate properly rests with the school board.” Id. Accordingly, Fraser establishes an exception to Tinker’s disruption requirement. Under Fraser, the banned school speech need not meet Tinker ’s disruption requirement; rather, speech in school can be banned if it is lewd, vulgar, indecent, or plainly offensive. Id. at 685, 106 S.Ct. 3159; see also Saxe, 240 F.3d at 213 (<HOLDING>); Boroff v. Van Wert City Bd. of Ed., 220 F.3d 
 Holding statements: (A) holding that first amendment barred school from punishing student for vulgar myspace post concerning principal be cause it was offcampus speech (B) recognizing obscene and indecent have different meanings and indecent speech may be regulated under some circumstances without transgressing the first amendment (C) holding that university violated first amendment by expelling student for printing indecent newspaper despite student code prohibiting indecent conduct or speech (D) holding that under fraser there is no first amendment protection for lewd vulgar indecent and plainly offensive speech in school (E) recognizing school officials ability to act for the protection of minors from exposure to vulgar and offensive spoken language

Answer:
holding that first amendment barred school from punishing student for vulgar myspace post concerning principal be cause it was offcampus speech