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.

if a defendant’s will has been overborne, we must assess “the conduct of the law enforcement officials in creating pressure and the suspect’s capacity to resist that pressure”; “[t]he defendant’s personal characteristics as well as his prior experience with the criminal justice system are factors to be considered in determining [the defendant’s] susceptibility to police pressures.” Jackson, 562 So.2d at 1380-81 (citations omitted). The evidence does not indicate that McLeod was threatened with physical intimidation or psychological pressure. The evidence does not show that the interrogation lasted for an extraordinary length of time or that he was deprived of either food or sleep for an unexplained and prolonged time. See, e.g., Pardue v. State, 695 So.2d 199 (Ala.Crim.App.1996) (<HOLDING>). Further, the evidence does not show that 
 Holding statements: (A) holding that a confession obtained by interrogating the defendant for approximately 78 hours was involuntary (B) holding involuntary a confession obtained by prison psychologist because the defendant reasonably understood that his communications would remain confidential (C) holding that mental coercion led to an involuntary confession (D) holding that under elstad the first question that must be answered when determining whether a subsequent confession is tainted by an earlier confession is whether the initial confession was obtained in violation of the defendants fifth amendment rights  ie whether it was involuntary  or whether the confession was voluntary but obtained in technical violation of miranda  (E) holding that impermissible police procedures rendered confession involuntary
holding involuntary a confession obtained by prison psychologist because the defendant reasonably understood that his communications would remain confidential

Supreme Court rejected Cook’s claim of error on direct appeal, finding that the prosecutor’s comments were not directed at Cook’s decision not to testify, and that the comment about the videotape was invited by Cook’s cross-examination and argument. Cook, 821 P.2d at 741-43. The district court agreed that the comments were either comments on the state of the evidence or invited by Cook’s arguments and cross-examination. In addition, the district court found that, if there was error, it was harmless under Brecht v. Abrahamson, 507 U.S. 619, 631, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993). Comment on the refusal to testify at trial violates a defendant’s Fifth Amendment right against self-incrimination. See Griffin v. California, 380 U.S. 609, 615, 85 S.Ct. 1229, 14 L.Ed.2d 106 (1965) (<HOLDING>). Also, a prosecutor’s comment on a defendant’s 
 Holding statements: (A) recognizing that the fifth amendment forbids comment by the prosecution on a defendants failure to testify (B) holding that it is improper for prosecutor to comment on accuseds postarrest silence (C) holding fifth amendment prohibits comment on accuseds silence during police custodial interrogation (D) holding fifth amendment prohibits comment on accuseds testimonial silence (E) holding that the fifth amendment  forbids either comment by the prosecution on the accuseds silence or instructions by the court that such silence is evidence of guilt
recognizing that the fifth amendment forbids comment by the prosecution on a defendants failure to testify

and his access to the records of the other allotments in the area, [Native American # 1] was given an allotment that obviously conflicted with a prior land claim. No matter how much [Native American # 1] or his survivors might have wished to cultivate this land [as required by statute], it would have been virtually impossible because of this conflict. Id. at 1166. For this reason, the court concluded that it would protect the plaintiff’s interests by holding that the plaintiff’s predecessors complied with the statutory requirements necessary to acquire a vested interest in the allotted land. Id. at 1167. Here, a finding in favor of Cabrera is even more compelling because there is evidence that he did, in fact, comply with the requirements of his permit. 54 Cf. Antoine, 710 F.2d at 479 (<HOLDING>). 55 N.M.I. Const, art. Xm, §§ 1-2 (the 
 Holding statements: (A) holding that under the statute of frauds a description will be insufficient as a matter of law if it is indefinite to the degree that no particular tract of land is identified nevertheless a description which is vague will be sufficient if its precise location may be determined upon competent parol evidence (B) holding that the federal government was liable for a taking of property where california officials acting under the authority of a federal order occupied land (C) holding that if subsequent to the taking and before the trial the ordinance was actually amended to permit the previously forbidden use then that of  itself was weighty evidence of the existence at the time of the taking of the fact that there was a reasonable probability of an imminent change (D) holding that governments conduct constituted a taking where the government erroneously confirmed native american ls selection pursuant to treaty of a tract of land that was previously selected by native american  2 whose possession of the tract prevented native american  1 from complying with statutory requirements for issuance of a patent (E) holding that where both tract to which predecessor had record title and disputed tract were enclosed by single fence even though deed from predecessor to plaintiffs described only tract of record and possession of both tracts was delivered by predecessor to plaintiffs who continued to adversely possess disputed tract there was privity of estate between predecessor and plaintiffs who were entitled to tack their period of adverse possession onto that of predecessor to get full statutory tenyear period

holding that under the statute of frauds a description will be insufficient as a matter of law if it is indefinite to the degree that no particular tract of land is identified nevertheless a description which is vague will be sufficient if its precise location may be determined upon competent parol evidence