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: Executone Info. Sys., Inc. v. Davis, 26 F.3d 1314, 1320 (5th Cir.1994))). 17 . See Executone, 26 F.3d at 1320 ("We must sustain an arbitration award even if we disagree with the arbitrator’s interpretation of the underlying contract as long as the arbitrator’s decision 'draws its essence' from the contract.” (internal quotation marks and citation omitted)). 18 . See also Parsons & Whittemore, 744 F.2d at 1483-84 (recounting that the arbitration panel awarded postjudgment interest at state statutory rate). 19 . We construe the parties’ intentions "generously” to determine whether they agreed to arbitrate a particular issue. See Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 626, 105 S.Ct. 3346, 87 L.Ed.2d 444 (1985). 20 . Cf. Newmont, 615 F.3d at 1272, 1276 (<HOLDING>). 21 . Riebesell, 586 F.3d at 794; 
 Holding statements: (A) holding that court should consider issues relating to making and performance of agreement to arbitrate (B) holding that because the parties agreed to arbitrate and both placed the issue before the arbitrator the issue of consolidation was for the arbitrator (C) holding that because the parties agreed to arbitrate the particular issue any doubt about who should decide the consolidation issue was resolved in favor of the arbitrator (D) holding that companys contention that union repudiated the agreement to arbitrate a particular dispute was a matter for the arbitrator and not the court to decide (E) holding that agreement to arbitrate any dispute arising out of contract authorized arbitrator to decide postjudgment interest issues

A: holding that court should consider issues relating to making and performance of agreement to arbitrate
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Q: in calculating the reduction of state workers’ compensation benefits advances the legislature’s intent to reduce the state’s compensation burden by taking advantage of the workers’ compensation government benefits offset to its fullest extent. Accordingly, we hold that SSDI child’s benefits are to be included when calculating the amount of the reduction in an employer’s payment of workers’ compensation benefits under Minn.Stat. § 176.101, subd. 4. II. The Fund makes the argument that the WCCA exceeded its authority in examining the Social Security Act. The WCCA’s jurisdiction does not extend to interpreting or applying legislation designed specially for the handling of claims outside the workers’ compensation system. Taft v. Advance United Expressways, 464 N.W.2d 725, 727 (Minn.1991) (<HOLDING>). In that Minn.Stat. § 176.101, subd. 4, is a 
 Holding statements: (A) holding that the primary goal when interpreting an insurance contract is to ascertain the intent of the parties as manifested by the language of the specific insurance policy (B) holding that under minnesota law an insurance policy or provision not filed with the commissioner of insurance is unenforceable (C) holding that the tucker acts waiver of sovereign immunity for contract claims does not extend to claims for contracts implied in law (D) holding that the tucker acts waiver does not extend to statutory claims (E) holding that the jurisdiction of the wcca did not extend to interpreting or applying the law related to claims against the minnesota insurance guaranty association

A: holding that the primary goal when interpreting an insurance contract is to ascertain the intent of the parties as manifested by the language of the specific insurance policy
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Q: Mr. Muniz contends that, because Colorado defendants typically assert ineffective assistance claims upon collateral review, a collateral proceeding is effectively the first tier of review and counsel must be provided. Although, as Mr. Muniz notes, Halbert v. Michigan, 545 U.S. 605, 125 S.Ct. 2582, 162 L.Ed.2d 552 (2005), extended the right to counsel to a class of discretionary direct appeals, Halbert did not overrule clearly established Supreme Court precedent that individuals have no right to counsel in post-conviction proceedings. Id. at 2591-92. See, e.g., Coleman v. Thompson, 501 U.S. 722, 755, 111 S.Ct. 2546, 115 L.Ed.2d 640 (1991) (“[T]here is no right to counsel in state collateral proceedings.”); Murray v. Giarratano, 492 U.S. 1, 13, 109 S.Ct. 2765, 106 L.Ed.2d 1 (1989) (<HOLDING>); Pennsylvania v. Finley, 481 U.S. 551, 557, 
 Holding statements: (A) holding that defendants have a right to counsel in criminal proceedings (B) holding no right to counsel for capital defendants in state habeas proceedings (C) holding that even capital prisoners have no constitutional right to counsel in habeas cases (D) recognizing the common practice of substituting specialized capital counsel for habeas petitions filed by capital defendants (E) holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel

A:
holding that defendants have a right to counsel in criminal proceedings
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