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.

Q: but rather affords a bright-line, legal presumption of coercion, requiring suppression of all unwarned statements.” Oregon v. Elstad, 470 U.S. 298, 306 n. 1, 105 S.Ct. 1285, 1292 n. 1, 84 L.Ed.2d 222, 23 2 L.Ed.2d 975 (1958) (same). Essentially, the Court determined that the prejudicial quality of testimony regarding an actually coerced confession is, like all other improperly introduced testimony at trial, capable of review. At this point in time, the Fulminante decision stands as the sole, albeit the dispositive, case on this point. In contrast, cases applying the harmless error analysis to the introduction of presumptively coerced statements are legion. See e.g. Pennsylvania v. Muniz, 496 U.S. 582, 605 & n. 22, 110 S.Ct. 2638, 2652 & n. 22, 110 L.Ed.2d 528, 555 & n. 22 (1990) (<HOLDING>); Berkemer v. McCarty, 468 U.S. 420, 443, 104 
 Holding statements: (A) holding that waiver of miranda rights was valid where  finding  that the defendant initiated the conversation  was  implicit in the district judges denial of the suppression motion  (B) holding that in order to conclude that federal constitutional error is harmless court must find that error harmless beyond a reasonable doubt (C) holding that booker constitutional error was harmless beyond a reasonable doubt because on remand the district court would have given defendant the same sentence (D) holding that although defendant was a deputy sheriff miranda warnings were required irrespective of defendants knowledge of his fifth amendment rights (E) holding that although miranda required the suppression of testimonial statements made before defendant was advised of his constitutional rights the state court is free of course to consider this harmless error question upon remand

A: holding that waiver of miranda rights was valid where  finding  that the defendant initiated the conversation  was  implicit in the district judges denial of the suppression motion 
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Q: California state prisoner, Roy Lee Brown, Jr., appeals pro se the dismissal of his 28 U.S.C. § 2254 petition as untimely. We have jurisdiction pursuant to 28 U.S.C. § 2253. We review de novo, see Miles v. Prunty, 187 F.3d 1104, 1105 (9th Cir.1999), and we vacate and remand. Brown contends that his § 2254 petition was timely filed because his state habeas petitions statutorilly tolled the Antiterrorism and Effective Death Penalty Act’s (AEDPA) one-year statute of limitations. We agree. Brown is entitled to tolling during the time he was seeking one full round of collateral review by the California courts. See 28 U.S.C. § 2244(d); Delhomme v. Ramirez, No. 00-56148, 2003 WL 21947183, at *3 (9th Cir. Aug. 15, 2003) (per curiam) (<HOLDING>); Carey v. Saffold, 536 U.S. 214, 220, 122 
 Holding statements: (A) holding that second and third state habeas petitions that were dismissed as impermissible successive petitions were properly filed (B) holding that it would be inappropriate to predict whether state law would foreclose state postconviction review of the petitioners habeas claim where the state permitted second or successive state petitions when the procedural bar would result in fundamental injustice (C) recognizing that a habeas petitioner may be entitled to tolling during a second round of petitions but holding that the statute is not tolled between rounds (D) holding that overlapping state habeas petitions begin a separate round of review and do not disturb the pendency of petitioners first round of review (E) holding that overlapping petitions do not affect tolling during the time petitioner is seeking one full round of review

A: holding that second and third state habeas petitions that were dismissed as impermissible successive petitions were properly filed
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Q: the future because she continues to own and operate Helping Hands and intends to remain in the childcare services profession. Docket No. 17 at ¶ 112. She posits no other basis for establishing her standing to seek prospective relief against the Secretary. Docket No. 26 at 6-9. Her status as the owner and operator of a child-care facility does not provide her with standing to seek the declaratory and injunctive relief that she seeks. Mosby v. Ligon, 418 F.3d 927, 933-934 (8th Cir.2005) (recognizing that an attorney’s status as a member of the bar does not afford him or her standing to prospectively attack the implementation of the professional disciplinary procedures applicable to attorneys practicing in a particular jurisdiction); Brown v. Fauver, 819 F.2d 395, 400, n. 5 (3d Cir.1987) (<HOLDING>). Burns does not allege that she has been 
 Holding statements: (A) holding that counsel cannot raise his or her own ineffectiveness (B) holding that plaintiff must on his or her own initiative prove that the product reached him or her without substantial change (C) holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence (D) holding that a prisoner cannot establish his or her standing to prospectively challenge the validity of a facilitys disciplinary procedures simply by referring to his or her status as an individual incarcerated in that facility (E) holding that an expert can comply with the timing requirement if an experts research even after his or her deposition revealed that the standard of care in his or her community was the same or similar to the standard of care in the community in which he or she is testifying when the injury occurred

A:
holding that counsel cannot raise his or her own ineffectiveness
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