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.

[EX Q]: clause could be vitiated based on evidence of fraud “relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs’ allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 (“Fraud ... makes a contract voidable at the instance of the innocent party.”) (quoting 3 Corbin, Contracts, § 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs’ argument conflates their tort 
 Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable
[EX A]: holding that a contract made in violation of section 432070 is void rather than voidable

[EX Q]: (Tex.2010) (orig. proceeding). Failure to exhaust administrative remedies creates a jurisdictional bar to proceeding with the claim. See City of Waco v. Lopez, 259 S.W.3d 147, 154 (Tex.2008) (“[Njoncompliance [with Chapter 21’s administrative procedures] deprives courts of subject-matter, jurisdiction.”); Smith v. Univ. of Tex. Sw. Med. Ctr. of Dallas, 101 S.W.3d 185, 188 (Tex.App.-Dallas 2003, no pet.). A would-be Chapter 21 claimant must first file an administrative complaint with the civil rights division of the Texas Workforce Commission. See Tex. Lab.Code Ann. § 21.201(a) .(stating that an aggrieved person “may file a complaint with the commission”); id. § 21.0015 (defining “commission” as “the Texas Workforce ■Commission civil rights division”); Schroeder, 813 S.W.2d at 486-88 (<HOLDING>). The complaint must be filed “not later than 
 Holding statements: (A) holding use of word may generally indicates permissive rather than mandatory intent (B) holding that a states use of the word shall is mandatory language (C) holding that exhaustion is mandatory and jurisdictional (D) holding that administrative exhaustion is mandatory despite legislatures use of the word may (E) recognizing that exhaustion is mandatory and jurisdictional
[EX A]: holding use of word may generally indicates permissive rather than mandatory intent

[EX Q]: at 634, the Supreme Court made a similar observation about the offending portion of the Violence Against Women Act, noting further that “Lopez makes clear” that such a jurisdictional element would have lent support to the constitutionality of the Act. Morrison, 529 U.S. at 613, 120 S.Ct. 1740. The felon-in-possession statute, on the other hand, has a jurisdictional element that has been considered by the Supreme Court in United States v. Bass, 404 U.S. 336, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971), and Scarborough v. United States, 431 U.S. 563, 97 S.Ct. 1963, 52 L.Ed.2d 582 (1977), the latter case holding that only a minimal nexus with interstate commerce satisfies the interstate commerce requirement of the felon-in-possession statute (then 18 U.S.C. § 1202). See Lemons, 302 F.3d at 770-71 (<HOLDING>). Wolvin asks us to read the holding of Lopez 
 Holding statements: (A) recognizing application of the doctrines may involve a fact question for the jury but not finding such a question in the case before it (B) recognizing that the supreme court maintained the trial courts fact finding authority without setting a new standard in booker (C) recognizing that the supreme court in those cases was principally concerned with congressional intent but finding that the constitutional question was not far from the courts mind (D) holding that the district courts finding of no discrimination was not clearly erroneous because the finding was supported by the record (E) holding that although not essential to the outcomes of two previous cases the court of appeals should have followed the texas supreme courts statements in those cases
[EX A]:
recognizing application of the doctrines may involve a fact question for the jury but not finding such a question in the case before it