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.

Example Input: of the evidence to have determined the outcome.” Id.; accord Snow v. State, 697 S.W.2d 663, 666-68 (Tex.App.-Houston [1st Dist.] 1985), pet. dism’d, 794 S.W.2d 371 (Tex.Crim.App.1987). A “single egregious error” may constitute ineffective assistance. Thompson, 9 S.W.3d at 813. Frequently, it has. Texas Cases Reversing Without Evidence of Trial Strategy In at least 22 cases decided after the Court of Criminal Appeals decided Jackson v. State, Texas courts have reversed even though no evidence of trial counsel’s reasoning was presented. See Woods v. State, 59 S.W.3d 833, 835-38 (Tex.App.-Texarkana 2001, pet. filed); Mares v. State, 52 S.W.3d 886, 893 (Tex.App.-San Antonio 2001, pet. ref'd); Jaubert v. State, 65 S.W.3d 73 (Tex.App.-Waco 2000, pet. granted) (designated for publication) (<HOLDING>); Robison v. State, 35 S.W.3d 257, 265 
 Holding statements: (A) recognizing rule (B) recognizing a limited exception to the eightcorners rule for a pure coverage question where the insurer is not questioning the merits of the underlying thirdparty claim and the extrinsic evidence goes strictly to an issue of coverage without contradicting any allegation in the thirdparty claimants pleadings material to the merits of that underlying claim (C) recognizing that sanctions are collateral to the merits of the case and may be considered even after the merits are no longer before the district court (D) holding that procedural bar rule does not apply to ineffectiveness claims (E) recognizing the rule in robinson and reviewing the merits of ineffectiveness claim without evidence of trial counsels strategy
Example Output: recognizing rule

Example Input: court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts
Example Output: holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort

Example Input: we find that there is a reasonable interpretation of the statutes involved that avoids an inconsistency and gives effect to both statutes. Plaintiffs cause of action is based on the Act. As such, the only limitations period applicable to her claim is the two-year statute of limitations period found in section 2 of the Act. Thus, plaintiff had two years from the date of her husband’s death to file a wrongful death action provided that plaintiffs decedent had a claim that was not time-barred at the time of his death. For purposes of determining whether plaintiffs decedent had a claim that was time-barred at the time of his death, we use the limitations period found in section 13 — 214(a), which applies to construction d 621, 628 (1989), aff’d on other grounds, 146 Ill. 2d 477 (1992) (<HOLDING>). Plaintiff also finds support for her position 
 Holding statements: (A) holding that statute of limitations for contribution actions found in section 13  204 of the code applies over limitations period for malpractice actions found in section 13  212 of the code where the plaintiffs complaint was based solely on contribution act ill rev stat 1985 ch 70 par 301 et seq section 13  204 is more specific than section 13  212 (B) holding that the limitations period in section 13  214a takes precedence over the limitations period for personal injuries found in section 13  202 of the code (C) holding that limitations period in section 13  214a of the code applies over limitations period for contribution actions found in section 13  204 of the code because former provision is more specific (D) holding that the then twoyear statute of limitations for constructionrelated actions found in section 13  214a of the code applies over the fiveyear statute of limitations period for certain actions found in section 13  205 of the code (E) holding merck applies to section 13 of the securities act
Example Output:
holding that the limitations period in section 13  214a takes precedence over the limitations period for personal injuries found in section 13  202 of the code