instruction:
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.
question:
this Opinion. Accordingly, it is ORDERED that the Trustee’s Objection to the Debtor’s Claim of exemption in her Toledo, Ohio house, pursuant to 11 U.S.C. § 522(d)(1), be, and is hereby, SUSTAINED. It is FURTHER ORDERED that the Trustee’s Objection to the Debtor’s claim of exemption in past due rents, pursuant to 11 U.S.C. § 522(d)(5), be, and is hereby, DISMISSED without prejudice. 1 . As a resident of Michigan, the Debtor along with her bankruptcy petition also filed a contemporaneous motion for a change of venue to the Northern District of Ohio, Western Division, which this Court granted. 2 . Pursuant to § 522(b), a debtor's right to claim an exemption in bankruptcy is determined by the state in which the debtor is domiciled. See In re Vaughan, 188 B.R. 234, 237 (Bankr.E.D.K.y.1995) (<HOLDING>). Some states like Michigan permit their 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that the terms residence and domicile are not the same thing but that a debtor may only claim an exemption in property where he is domiciled (C) holding that a bankruptcy debtor may claim the homestead exemption for real property transferred to a selfsettled revocable trust even though the settlor and the beneficiary as well as the bankruptcy debtor were the same person (D) holding that the objector must not only show that the facts do not support the exemption but must also prove that the debtor knowingly deceived the trustee and the creditors at the time the exemption was made (E) holding despite contrary authority that husband debtor with a mere possessoiy interest was not entitled to claim a homestead exemption and stating it is a fundamental tenet of the law of exemptions that the debtor must have an ownership interest in the property before an exemption may be claimed a long line of illinois cases has required that a debtor have title or some ownership interest in property in order to claim a homestead exemption other courts deciding the issue under the federal exemption scheme have held that the key word is interest and that an interest in real property up to a specified amount implies a monetary interest more than just one spouses right to reside with the other
answer:
holding that spouse could not claim exemption in property that was only property of other spouses estate


question:
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
answer:
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


question:
this conclusion, we are mindful of decisions in other jurisdictions rejecting the argument that changes to the juvenile justice system have altered its parens patriae character. See Valdez v. State, 33 Ark. App. 94, 801 S.W.2d 659 (1991); In re Myresheia W., 61 Cal. App. 4th 734, 72 Cal. Rptr. 2d 65 (1998); In re L.C., 273 Ga. 886, 548 S.E.2d 335 (2001); State, ex rel. D.J., 817 So. 2d 26 (La. 2002) (dissenting justice concluded changes to system required a jury trial); State v. G 971) (upholding statute that required juvenile trials to be heard by the court; concurring justice acknowledged that if juvenile code became only a punitive tool, then a juiy trial might be justified under state constitution); State v. Hezzie R., 219 Wis. 2d 848, 887, 889-90, 919, 580 N.W.2d 660 (1998) (<HOLDING>). While there is wide variability in the 
 Holding statements: (A) holding juveniles do not have constitutional right to a jury trial but striking down statute that allowed juveniles to receive adult sentence without a jury trial three justices dissented reasoning juveniles should be entitled to a juiy trial under all cases because changes to juvenile justice code treated juveniles like criminals (B) recognizing juveniles right to counsel in certain juvenile proceedings (C) holding that juveniles are not entitled to jury trials (D) holding that juveniles may waive constitutional rights (E) holding juveniles do not have right to jury trial because it is a civil proceeding under states parens patriae authority four justices dissented
answer:

recognizing juveniles right to counsel in certain juvenile proceedings