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.
--------
Question: was merely a voidable act. They rely on Sikes v. Global Marine, Inc., 881 F.2d 176 (5th Cir.1989), rehearing denied by 888 F.2d 1388 (5th Cir.1989), in which the Fifth Circuit found that the filing of a complaint in violation of the stay was voidable but not void. Id. at 178-79. The court reasoned that provisions of the Bankruptcy Code such as section 362(d), by giving courts the power to grant retroactive relief from a stay, indicated Congressional intent that acts in violation of a stay be simply voidable. Id. Spring Meadows, however, urges us to adopt the rule of the Ninth Circuit that any act committed in violation of an automatic stay is void. Hillis Motors, Inc. v. Hawaii Auto. Dealers Ass’n, 997 F.2d 581, 586 (9th Cir.1993); In re Schwartz, 954 F.2d 569, 571-72 (9th Cir.1992) (<HOLDING>). The circuit court found such acts void even 
 Holding statements: (A) recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect (B) holding that violations of the automatic stay are void and rejecting the reasoning of sikes (C) holding judgment in violation of automatic stay void (D) holding that the automatic stay did not bar the filing of a proof of claim where the debtor actively litigated a separate action during the pending bankruptcy proceeding because to permit the automatic stay provision to be used as a trump card played after an unfavorable result was reached  would be inconsistent with the underlying purpose of the automatic stay (E) holding that an action taken in violation of the automatic stay is void ab initio

Answer: recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect


Question: reviews de novo the application of the law to those facts.” Mungin v. State, 982 So.2d 986, 998 (Fla.2006). A. Stipulating to Evidence for the Motion to Suppress Parker’s May 7, 1982, Statement In this claim, Parker contends that trial counsel was ineffective for stipulating to the evidence used to decide whether his May 7, 1982, statement was admissible. Parker’s May 7 statement was admitted during the resentencing proceeding through the testimony of Detective Powers. Because Parker had invoked his right to counsel prior to making the May 7 statement, the admissibility of that statement under United States Supreme Court precedent turns on whether Parker initiated the May 7 contact with law enforcement. See Edwards v. Arizona, 451 U.S. 477, 484-85, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981) (<HOLDING>). The stipulated evidence included hearsay 
 Holding statements: (A) holding that under the fifth amendment once an accused person in custody has expressed his or her desire to deal with the police only through counsel that person is not subject to further interrogation by the authorities until counsel has been made available  unless the accused himself initiates further communication exchanges or conversations with the police (B) holding that when an accused has invoked his right to have counsel present during custodial interrogation a valid waiver of that right cannot be established by showing only that he responded to further policeinitiated custodial interrogation even if he has been advised of his rights an accused  having expressed his desire to deal with the police only through counsel is not subject to further interrogation by the authorities until counsel has been made available to him unless the accused himself initiates further communication exchanges or conversations with the police (C) holding that edwards precludes further interrogation unless he the accused himself initiates further communications (D) holding that subsequent to an invocation of counsel the edwards per se rule does not apply if an accused himself initiates further communication exchanges or conversations with the police (E) holding that an accused who has invoked the right to counsel is not subject to further interrogation unless the accused himself initiates further communication exchanges or conversations with the police

Answer: holding that when an accused has invoked his right to have counsel present during custodial interrogation a valid waiver of that right cannot be established by showing only that he responded to further policeinitiated custodial interrogation even if he has been advised of his rights an accused  having expressed his desire to deal with the police only through counsel is not subject to further interrogation by the authorities until counsel has been made available to him unless the accused himself initiates further communication exchanges or conversations with the police


Question: we hold that Plaintiff has alleged sufficient facts to state a claim to enforce these covenants as equitable servitudes unless some additional, more precise standards are legally necessary to define and restrict Plaintiffs power of approval. THE DEVELOPER’S POWER OF APPROVAL 16. Defendants contend that the equitable servitudes are unenforceable because the Declaration contains no clear standards for the developer to apply when deciding to approve or disapprove of a particular mobile home. This is an issue of first impression in New Mexico. 17. Some jurisdictions require reasonable parameters in the form of written or de facto guidelines to show that the approving authority is acting reasonably. See Town & Country Estates Ass’n v. Slater, 227 Mont. 489, 740 P.2d 668, 671 (1987) (<HOLDING>); Prestwick Landowners’ Ass’n v. Underhill, 69 
 Holding statements: (A) holding that a restrictive covenant with a tenyear term was unenforceable (B) holding that property owner who violated restrictive covenant multiple times over several years waived enforcement of same restriction against third parties as matter of law (C) holding that a state law requiring benefit plans to include minimum benefits related to erisa plans (D) holding that a restrictive covenant requiring approval of building plans by homeowners association which failed to define standard of approval was too vague for enforcement (E) holding that a restrictive covenant with worldwide restrictions on competition is not reasonable

Answer:
holding that a restrictive covenant with a tenyear term was unenforceable