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.

[EX Q]: Discipl. LEXIS 78, *9 (attorney disbursed all settlement proceeds to client less amount he retained for himself, after having been placed on notice that prior attorney claimed an in terest in any settlement funds in violation of Colo, RPC 1.15(b)). III. ANALYSIS OF SANCTION In both the Dunn and McCarthy matters, Rishel engaged in knowing conversion by obtaining funds from third parties for a stated purpose, failing to utilize the funds for that purpose, retaining the funds for an extended period of time after the third parties had withdrawn authorization, and failing to refund the amounts paid to the third parties despite their demand that he do so. The presumptive sanction for knowing conversion of the property of another is disbarment. People v. Dice, 947 P.2d 339, 340 (Colo.1997)(<HOLDING>); Motsenbocker; 926 P.2d at 577 (attorney 
 Holding statements: (A) holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause (B) holding that a lawyers knowing misappropriation of funds whether belonging to a client or third party warrants disbarment except in the presence of extraordinary factors of mitigation (C) holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors the attorneys clients did not suffer actual harm and the attorney established several mitigating factors (D) holding that permanent disbarment was appropriate for failure to remit 2000 in settlement funds to client and failing to answer the charges (E) recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person
[EX A]: holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause

[EX Q]: 558, 563, 564 S.E.2d 94, 96 (2002). DISCUSSION Moody argues the circuit court erred in granting Dairy-land’s motion for summary judgment, asserting Dairyland did not make a meaningful offer of UIM coverage because it failed to offer coverage in amounts less than the statutory minimum limits. We disagree. “The cardinal rule of statutory construction is to ascertain and effectuate the intent of the legislature.” Hawkins v. Bruno Yacht Sales, 353 S.C. 31, 40, 577 S.E.2d 202, 207 (2003).. Moreover, “[w]here the terms of the statute are clear, [this Court] must apply those terms according to their literal meaning.” Brown v. South Carolina Dep’t of Health & Envtl. Control, 348 S.C. 507, 515, 560 S.E.2d 410, 414 (2002); see also Rowe v. Hyatt, 321 S.C. 366, 369, 468 S.E.2d 649, 650 (1996) (<HOLDING>). In relevant part, section 38-73-470 provides 
 Holding statements: (A) holding that the clear and unambiguous words of an insurance contract should be given their plain and ordinary meaning (B) holding that we must give the words in statutes their plain and ordinary meaning (C) holding when interpreting a statute words must be given their plain and ordinary meaning without resorting to subtle or forced construction to limit or expand the statutes operation (D) holding that where the language of a statute is clear and without ambiguity the plain meaning is to be accepted without resorting to the rules of interpretation (E) holding that statutory words must be given their ordinary contemporary meaning
[EX A]: holding that the clear and unambiguous words of an insurance contract should be given their plain and ordinary meaning

[EX Q]: therefore “is repugnant to the guaranty of liberty contained in the Fourteenth Amendment.” Id. Similarly, in Lovell v. Griffin, 303 U.S. 444, 58 S.Ct. 666, 82 L.Ed. 949 (1938), the Court struck down as facially invalid a local ordinance that required a license to distribute any literature and gave the chief of police the power to deny a license. 303 U.S. at 451-52, 58 S.Ct. 666. The Court held that the ordinance “strikes at the very foundation of the freedom of the press by subjecting it to license and censorship.” Id. at 451, 58 S.Ct. 666. In New York State Club Ass'n, Inc. v. City of New York, however, the Supreme Court declined to find a law facially unconstitutional because plaintiffs could not establish that the law was unconstitutional in all of its applicati 848, 855 (Minn.1991) (<HOLDING>). Those who support this view conclude that the 
 Holding statements: (A) holding blood testing for alcohol content a search (B) holding that blood alcohol content almost 30 over the limit together with testimony of intoxication at the time of driving was sufficient to convict contrasting a case in which the blood alcohol content was just barely over the limit which was insufficient to convict (C) holding a minnesota statute that required police to advise drivers that they were not permitted to consult with an attorney prior to deciding whether to submit to or refuse blood alcohol content testing and one that imposed criminal penalties on individuals who refused to submit to blood alcohol testing within five years of a prior drivers license revocation unconstitutional as applied (D) holding search of blood alcohol tests not permitted under section 1547 where suspect under arrest and police did not request testing (E) holding that the fourth amendment is implicated by the withdrawal of blood to test its alcohol content
[EX A]:
holding blood testing for alcohol content a search