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: the future because she continues to own and operate Helping Hands and intends to remain in the childcare services profession. Docket No. 17 at ¶ 112. She posits no other basis for establishing her standing to seek prospective relief against the Secretary. Docket No. 26 at 6-9. Her status as the owner and operator of a child-care facility does not provide her with standing to seek the declaratory and injunctive relief that she seeks. Mosby v. Ligon, 418 F.3d 927, 933-934 (8th Cir.2005) (recognizing that an attorney’s status as a member of the bar does not afford him or her standing to prospectively attack the implementation of the professional disciplinary procedures applicable to attorneys practicing in a particular jurisdiction); Brown v. Fauver, 819 F.2d 395, 400, n. 5 (3d Cir.1987) (<HOLDING>). Burns does not allege that she has been 
 Holding statements: (A) holding that counsel cannot raise his or her own ineffectiveness (B) holding that plaintiff must on his or her own initiative prove that the product reached him or her without substantial change (C) holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence (D) holding that a prisoner cannot establish his or her standing to prospectively challenge the validity of a facilitys disciplinary procedures simply by referring to his or her status as an individual incarcerated in that facility (E) holding that an expert can comply with the timing requirement if an experts research even after his or her deposition revealed that the standard of care in his or her community was the same or similar to the standard of care in the community in which he or she is testifying when the injury occurred
Example Output: holding that counsel cannot raise his or her own ineffectiveness

Example Input: individual has breached a duty of reasonable care. Bolick v. Sunbird Airlines, Inc., 96 N.C. App. 443, 386 S.E.2d 76 (1989), aff'd, 327 N.C. 464, 396 S.E.2d 323 (1990). Sudden emergency does not change or reduce the standard of reasonable care. It is simply one of the factors to be considered in determining whether a person acted reasonably under the circumstances. Id. The sudden emergency doctrine permits the court to call to the attention of the jury that an emergency faced by the actor may influence its determination of whether specific conduct was reasonable under the circumstances. The doctrine of sudden emergency is not a legal defense which operates to bar an action. Id. But cf. Hinson v. Brown, 80 N.C. App. 661, 343 S.E.2d 284, rev. denied, 318 N.C. 282, 348 S.E.2d 138 (1986) (<HOLDING>). External forces that have been found to 
 Holding statements: (A) holding that trial court erred by instructing jury regarding sudden emergency (B) holding that sudden emergency is an affirmative defense which must be specifically plead (C) recognizing that mitigation of damages is an affirmative defense a party must plead and prove (D) holding that a claim of exemption is an affirmative defense which must be specifically pleaded (E) holding that to avoid an affirmative defense  a plaintiff must plead specifically matters of affirmative avoidance pursuant to rule 5508
Example Output: holding that trial court erred by instructing jury regarding sudden emergency

Example Input: But he claims that release at age 60 is a geriatric release and the functional equivalent of life without parole in violation of the Eighth Amendment. He also argues that such release violates the principles in Graham, Miller, and Montgomery because release at age 60 provides only grim prospects for any meaningful future outside prison. [¶12.] Even if Charles’s 92-year sentence is equivalent to a sentence of life without parole, that alone does not mean his sentence is unconstitutional under Eighth Amendment precedent. The United States Supreme Court bars mandatory life sentences without parole against juvenile homicide offenders, not discretionary sentences of life without parole. See Miller, 567 U.S. at -, 132 S.Ct. at 2469; State v. Springer, 2014 S.D. 80, ¶ 15, 856 N.W.2d 460, 466 (<HOLDING>). [¶13.] In response, Charles asks this Court 
 Holding statements: (A) holding sentences of life without parole unique in their severity (B) holding that graham which prohibited the imposition of a life without parole sentence on a juvenile offender who did not commit homicide does not apply to a lengthy termofyears sentence that might constitute a de facto life sentence (C) recognizing that njeither graham nor miller explicitly  apply to the functional equivalent of life without parole ie de facto life sentences (D) holding that consecutive fixedterm sentences for juveniles who committed multiple nonhomicide offenses are not clearly unconstitutional under graham even when they amount to the practical equivalent of life without parole (E) holding that williams fiftyyear sentence is not a de facto life sentence in violation of graham
Example Output:
holding sentences of life without parole unique in their severity