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: before section 362(b)(3) can come into play. An act that both creates and perfects a lien postpetition cannot so qualify. See, e.g., Louisville & Jefferson County Metro. Sewer Dist. v. Excel Eng’g, Inc. (In re Excel Eng’g, Inc.), 224 B.R. 582, 589-90 (Bankr.W.D.Ky.1998) (refusing to recognize validity of postpetition creation and perfection of mechanic’s hen because creditor had no lien at the time debtor filed for bankruptcy); Water-vliet Paper Co. v. City of Watervliet (In re Shoreham Paper Co.), 117 B.R. 274, 281-83 (Bankr.W.D.Mich.1990) (finding postpe-tition creation and perfection of property tax lien barred by automatic stay because no prepetition interest existed); Equitable Life Assur. Soc’y v. Ballentine Bros. (In re Ballentine Bros.), 86 B.R. 198, 201 (Bankr. D.Neb.1988) (<HOLDING>); North Side Lumber Co. v. Indus. Indem. Co. 
 Holding statements: (A) holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations (B) holding that the automatic stay would be modified so that a credit union could seek payment of postpetition interest from the codebtor (C) holding judgment in violation of automatic stay void (D) holding that creditors failure to voluntarily turn over property lawfully seized prepetition constituted violation of automatic stay (E) holding that creation of a postpetition tax levy based on a prepetition assessment was barred by the automatic stay
Example Output: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations

Example Input: this petition for prohibition. Petitioner is mistaken in an essential respect. Although he characterizes his challenge as involving subject matter jurisdiction, he is mistaken. There can be no dispute that the circuit court has subject matter jurisdiction over cases involving dissolution of marriage. See § 26.012(2)(a), Fla. Stat. (2006) (circuit courts have original jurisdiction in all actions at law not cognizable in the county courts). The fact that petitioner wishes to dispute in the pending dissolution action is whether there was any marriage at all to dissolve. An attack on the validity of an alleged marriage has nothing to do with subject matter jurisdiction but is simply an issue to be determined in the dissolution action. See Marden v. Marden, 276 So.2d 493 (Fla. 4th DCA 1973) (<HOLDING>). It is true that a petition for a writ of 
 Holding statements: (A) holding that there was a genuine issue of material fact precluding summary judgment (B) holding that standing existed (C) holding that in an action brought by alleged wife for permanent alimony suit money attorneys fees and restraining order an issue of fact existed concerning whether a commonlaw marriage existed thus precluding summary judgment (D) holding that material issue of fact existed concerning whether employer orally promised to discharge employee only for cause (E) holding that it was not an abuse of discretion for the court to deny an award of attorneys fees to the wife
Example Output: holding that there was a genuine issue of material fact precluding summary judgment

Example Input: for the greater crime. See State v. Shumway, 291 Or 153, 164, 630 P2d 796 (1981) (applying vertical proportionality to conclude that the portion of a sentence that required the defendant to serve a minimum of 25 years before being eligible for parole was invalid under Article I, section 16, because it required a lesser minimum sentence for aggravated intentional homicide than “unaggravated” intentional homicide); State v. Dobash, 210 Or App 145, 148, 149 P3d 1235 (2006) (determining that the defendant’s sentence was not unconstitutional because the maximum sentence allowed by law for first-degree theft was at least five years’ probation, which was greater than the four years’ probation that the defendant received for second-degree theft); State v. Koch, 169 Or App 223, 7 P3d 769 (2000) (<HOLDING>). In this case, defendant maintains that 
 Holding statements: (A) holding a 24month sentence for forgery unconstitutional because it exceeded the maximum sentence that the defendant could have received for a more serious forgery conviction (B) recognizing a claim that the sentence exceeded the statutory maximum (C) holding that an effective life sentence of fortyfive years for seconddegree forgery was excessive and that a life sentence was cruel and unusual in violation of the eighth amendment (D) holding statutory maximum for prior conviction is the potential maximum sentence defined by the applicable state criminal statute not the maximum sentence which could have been imposed against the particular defendant  according to the states sentencing guidelines (E) holding that a sentence imposed for a violation of supervised release will be upheld where 1 the district court considered the applicable policy statements 2 the sentence is within the statutory maximum and 3 the sentence is reasonable
Example Output:
recognizing a claim that the sentence exceeded the statutory maximum