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.

v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (2007). Kyler Road Home Charles first argues on appeal that the circuit court erred by not awarding him an interest in the home on Kyler Road. Although he acknowledges that Myra had acquired this property prior to the marriage, he asserts that he is entitled to an interest in the home because | ^marital funds were used to reduce the debt on the properly and to make improvements. Our definition of marital properly excludes property acquired before the marriage. Ark.Code Ann. § 9-12-315(b)(1) (Repl.2009). However, we have long held that a non-owning spouse is entitled to some benefit when marital funds have been expended to improve or reduce the debt on the other spouse’s nonmarital property. See Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (1993) (<HOLDING>); Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d 
 Holding statements: (A) holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property (B) holding that assets acquired subsequent to separation are not considered marital property absent evidence that spouse used marital property to obtain them (C) holding that separate property may become marital property if spouse donates it to marital unit with intent at time of donation that property become marital (D) holding that the trial court erred in finding that marital property was the former wifes separate property based on a nonseparation agreement in which the former husband purported to relinquish any interest in the marital property (E) holding that circuit court erred in failing to consider that marital property in the form of marital earnings was used to pay debt against nonmarital property
holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property

State v. Gill, 47 N.J. 441, 444, 221 A.2d 521 (1966))); Twp. of Pennsauken v. Schad, 160 N.J. 156, 170, 733 A.2d 1159 (1999). Our construction of N.J.S.A 39:4-88(b) is thus consonant with established principles of statutory construction. | IV. Applying statutes that are identical or very similar to the statute before the Court, courts of other states have reached varying conclusions. Several decisions have construed analogous statutes to describe two offenses, as this Court construes N.J.S.A 39:4-88(b). See People v. Butler, 81 Cal.App.3d Supp. 6, 146 Cal.Rptr. 856, 857 (Cal.Ct.App.1978) (construing Cal. Veh.Code § 21658 to state “two affirmative duties placed upon the operator of a motor vehicle”); People v. Smith, 172 Ill.2d 289, 216 Ill.Dec. 658, 665 N.E.2d 1215, 1218 (1996) (<HOLDING>); State v. Marx, 289 Kan. 657, 215 P.3d 601, 
 Holding statements: (A) holding that congress envisioned two separate petitions filed to review two separate final orders (B) holding that plain language of 625 ill comp stat ann 511709 establishes two separate requirements for lane usage (C) holding when ordinance language is clear courts must give language its plain meaning (D) holding that in context of motion for reconsideration or to reopen congress envisioned two separate timely petitions for review of two separate final orders (E) holding that the evidence supported two separate convictions and punishments for two attempted robberies of two different victims who suffered separate and distinct harms
holding that congress envisioned two separate petitions filed to review two separate final orders

v. al-Kidd, - U.S. -, 131 S.Ct. 2074, 2084, 179 L.Ed.2d 1149 (2011) (internal quotation marks omitted). Hence, the Second Circuit has from time to time cited case law from other circuits to show that courts generally were divided over the lawfulness of a particular behavior, as extra support for a finding that the behavior was not clearly unlawful. See Wilkinson, 182 F.3d at 107 n. 10 (citing case law from the Eighth Circuit to support conclusion that challenged behavior was not clearly unlawful at time); see also Doninger, 642 F.3d at 350 ("Finally, our conclusion that whatever right Doninger may have had was not clearly established is buttressed by the similarities between this case and the Sixth Circuit’s decision in Lowery v. Euverard, 497 F.3d 584 (6th Cir.2007), 10th Cir.2008) (<HOLDING>); Reasonover v. St. Louis Cnty., 447 F.3d 569, 
 Holding statements: (A) holding with respect to a general motion for directed verdict that it raised the question as to the sufficiency of the evidence on venue an essential part of the governments case internal quotation marks and citation omitted (B) holding that a ruling from a prior decision of this court becomes the law of the case that cannot be challenged in a later proceeding quotation marks omitted (C) holding that in the asylum context the bia must provide an individualized analysis of how changed conditions will affect the specific petitioners situation citation and internal quotation marks omitted (D) holding that the challenged conduct or statement must be directed at the familial relationship with knowledge that the statements or conduct will adversely affect that relationship internal quotation marks omitted (E) holding that a statute must be construed so that no part of the statute is rendered surplusage or superfluous internal quotation marks and citation omitted

holding with respect to a general motion for directed verdict that it raised the question as to the sufficiency of the evidence on venue an essential part of the governments case internal quotation marks and citation omitted