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.

Input: Consider Input: separate recording of the trust or declaration of trust. As there is no evidence on the face of the deeds indicating a. contrary intent, the Personal Representatives, pursuant to their fiduciary responsibilities, seek a declaration that, pursuant to section 689.07(1), Norman held fee simple title to the properties on the date of his death. These allegations are clearly sufficient under the plain language of the statute. See Raborn, 974 So.2d at 328 (stating that under section 689.07(1), a deed that simply refers to grantee as “trustee” conveys a fee simple estate, and applying the statute to find that deed at issue fell under “contrary intention” exception such that grantee held mere legal title as trustee); One Harbor Fin, Ltd. v. Hynes Props., LLC, 884 So.2d 1039 (Fla. 5th DCA 2004) (<HOLDING>); Heiskell v. Morris, 182 So.3d 714 (Fla. 1st 
 Holding statements: (A) holding that where grantee was named as trustee without identification of the beneficiaries or the nature and purposes of the trust and no trust agreement of record was identified the grantee received fee simple title (B) holding that debtor as grantor and trustee of a trust that held legal title to the property held a sufficient equitable interest in the property to claim it as exempt homestead where she resided on the property prepetition with the intent to maintain it as her primary residence (C) holding that trial court erred by granting surviving spouse fee simple title to estates exempt property (D) holding that trial court correctly applied section 689071 to find that grantee who held title as trustee owned property in fee simple absolute (E) holding that where individual held title to property as trustee but gave mortgage to bank in her individual capacity a title reference on the mortgage to the deed into her as trustee provided constructive notice that the mortgage was supposed to be from the individual as trustee or at the least that the holder of a subsequent interest would not be a bona fide purchaser

Output: holding that where grantee was named as trustee without identification of the beneficiaries or the nature and purposes of the trust and no trust agreement of record was identified the grantee received fee simple title


Input: Consider Input: judicial review of an arbitration award. See UHC Management Co., 148 F.3d at 998 (“ “We may not set an award aside simply because ... the arbitrators erred in interpreting the law or in determining the facts.’ ”) (quoting Stroh Container Co., 783 F.2d at 751). This third challenge is nonetheless partially cognizable, but only to the extent it can be read as an assertion that there was evident partiality or corruption in the arbitrators, a statutory ground under 9 U.S.C. § 10(a)(2), as a claim of misconduct by the arbitrators in refusing to hear evidence or to provide a reasonable opportunity to present evidence, another statutory ground under 9 U.S.C. § 10(a)(3), or as an extra-statutory challenge to the “fundamental fairness” of the proceedings. See P & P Indus., Inc., 179 F.3d at 870 (<HOLDING>). Hoffman’s fourth challenge is to the denial 
 Holding statements: (A) recognizing such a ground for judicial review of arbitration awards in this circuit (B) holding right to be fundamental (C) holding that section 34810 is an adequate and independent state ground (D) recognizing plain or fundamental error (E) recognizing review for fundamental unfairness of the proceedings as an independent extrastatutory ground

Output: recognizing such a ground for judicial review of arbitration awards in this circuit


Input: Consider Input: before it was in assumpsit for attorney fees purposes. See Schulz, 67 Haw. at 436, 690 P.2d at 282. Although Higa is not directly on point, its reasoning is a compelling indication of how the Hawaii Supreme Court would rule on the attorney fee question before us. The plaintiffs also seek to distinguish Higa because it involved a client suing his own attorney, and thus in that case there was privity of contract between the two parties. In the present case, Mrs. Helfand was a third-party beneficiary to the contract between the defendants and Mr. Helfand. This distinction is irrelevant. Courts have extended the right to sue for breach of contract to intended third-party beneficiaries. See, e.g., Dawes v. First Ins. Co. of Hawai'i, 77 Hawai'i 117, 128 n. 12, 883 P.2d 38, 48 n. 12 (1994) (<HOLDING>); Hunt v. First Insurance Co. of Hawaii, 82 
 Holding statements: (A) holding that thirdparty claimants are intended beneficiaries under optional automobile liability insurance policies (B) recognizing common law cause of action as thirdparty beneficiary (C) holding that the shareholders were not thirdparty beneficiaries because they were not directly benefited by the contract between the government and the thrifts (D) recognizing noncontracting parties rights as thirdparty beneficiaries of an insurance contract (E) holding that shareholders lack standing to sue as thirdparty beneficiaries to allegedly breached contract unless the contract indicates the intent to benefit them directly independently of their shareholder status


Output: holding that thirdparty claimants are intended beneficiaries under optional automobile liability insurance policies