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: 879 (citations omitted). We think there is a reasonable fit here between the State’s purpose of protecting society from persons who have been determined to be likely to reoffend if not placed in a secure facility and their placement in such a facility. Therefore, Garren has failed to show a substantive due process violation. VII. Vagueness. Although Garren states in a division heading in his brief that chapter 229A is vague as applied and on its face, he makes no argument in his brief in support of the contention that the statute is vague as applied to him. We deem this issue waived. See Iowa R.App.P. 14(a)(3) (“Failure in the brief to state, to argue or to cite to authority in support of an issue may be deemed waiver of that issue.”); State v. Cooley, 608 N.W.2d 9, 13-14 (Iowa 2000) (<HOLDING>). Consequently, Garren is precluded from 
 Holding statements: (A) holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief (B) holding issue waived where matter not addressed beyond reference in heading in brief (C) holding that an issue mentioned in a brief but not addressed is waived (D) holding issues argued orally but not addressed in brief were waived (E) holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned

Output: holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief


Input: Consider Input: to the exercise of discretion by the trial court. Penn s to avoid the appearance of impropriety is a worthy standard for professional conduct, a criminal defendant’s constitutional right to due process does not entitle him to a prosecution free of such appearances. Cf. Cuyler v. Sullivan, 446 U.S. 335, 348, 100 S.Ct. 1708, 1718, 64 L.Ed.2d 333 (1980) (stating that a defendant’s Sixth Amendment right to counsel is not violated when his lawyer has a “possible” or “potential” conflict of interest). Instead, a criminal defendant is denied due process only when his former counsel joins a Commonwealth’s Attorney’s office and is not effectively screened from contact with the Commonwealth’s attorneys who are handling the defendant’s case on a related matter. See Thompson, 246 So.2d at 763 (<HOLDING>); United States v. Goot, 894 F.2d 231, 236-37 
 Holding statements: (A) holding that even where a client was more sophisticated in business matters than the lawyer himself the lawyer should have assumed the client was relying on the lawyer for the legal aspects of the loan from the client to the lawyer to the same extent that the client would rely on the lawyer for advice were the client making the loan to a third person (B) holding than an attorney who serves as a mediator cannot subsequently represent anyone in a substantially related matter without the consent of the original parties because mediators routinely receive and preserve confidences in much the same manner as an attorney and where the mediator was privy to confidential information the applicable ethical rules impose the same responsibility as the rules relating to any attorneys subsequent representation of a former client (C) holding that defendants right to due process was not violated by the employment of his former counsel in the us attorneys office where the former counsel recused himself and was screened from the prosecution of defendants case (D) holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client (E) holding that a defendants due process rights are violated only if his former lawyer prosecutes him on a matter related to the representation or discloses client confidences to other prosecutors

Output: holding that even where a client was more sophisticated in business matters than the lawyer himself the lawyer should have assumed the client was relying on the lawyer for the legal aspects of the loan from the client to the lawyer to the same extent that the client would rely on the lawyer for advice were the client making the loan to a third person


Input: Consider Input: probation officers provided the courts, namely, “providing information in the course of the customer’s daily business operation[,] ... d[id] not relate to court policy or’ overall operational management but to the courts’ day-to-day production process.” Id. Thus, the court determined that the probation officers’ work did not directly relate to the management or general business operations of the employer. A strong argument can be made that the Investigators’ work in this case did not satisfy the directly related element for similar reasons.' It is of course true that while the primary duty of both the probation officers in Bratt and the Investigators before us was to conduct factual investigations and report their results, the information provided by the probation o 764 (4th Cir.1998) (<HOLDING>), with Shockley, 997 F.2d at 28-29 (holding 
 Holding statements: (A) holding experts experience knowledge and training is considered in determining reliability (B) holding that failure to furnish proper training instruction training manuals and documents to officer who injured plaintiff failure to provide adequate tests for that officer and failure to discipline that officer fell outside ttcas property waiver (C) recognizing an implied warranty in horse training because training introduces new elements to enhance the horses capabilities and personality and extinguishes undesirable traits (D) holding that ems training lieutenants position met criteria because the lieutenants developed coordinated implemented and conducted ems training programs  prepared lesson plans and training aids supervised delivery of training and tests and evaluated new equipment (E) holding that the plaintiff had offered insufficient evidence to establish deliberate indifference in a failuretotrain claim in part because the plaintiff did not present evidence that the training received was inadequate or evidence of any specific additional training that the employees should have received


Output: holding experts experience knowledge and training is considered in determining reliability