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: State, after expressing its clear and accurate understanding of the ... issue ..., deliberately steer[s] the District Court away from the question and towards the merits of [the] petition.” Wood v. Milyard, — U.S.-, 132 S.Ct. 1826, 1835, 182 L.Ed.2d 733 (2012) (internal citation omitted). In Wood, the state had assured the district court that it was “not challenging, but d[id] not concede, the timeliness of the petition.” Id. at 1830. As in Wood, the state’s words and conduct cannot be described as an inadvertent mistake or forfeiture of the exhaustion defense, as was the case in Day, but instead they clearly evidence an express intention to waive the exhaustion requirement. As the First Circuit said, “[t]hat was game, set, and match.” Pike v. Guarino, 492 F.3d 61, 71-72 (1st Cir.2007) (<HOLDING>). Other circuits have also held this type of 
 Holding statements: (A) holding that a deposition that was not presented to the trial court could not be considered on appeal (B) holding that nonconstitutional claims that could have been raised on direct appeal may not be asserted in a collateral proceeding (C) holding that a waived issue ordinarily cannot be resurrected on appeal whereas a forfeited issue may be reviewed for plain error (D) holding statement that  petitioner is correct in her assertion that the claims presented  have been exhausted  was unmistakably clear and could not be resurrected on appeal alteration in original (E) holding that complaint on appeal must be the same as that presented in the trial court
Example Output: holding that a deposition that was not presented to the trial court could not be considered on appeal

Example Input: in cases decided under the Bankruptcy Code. See, e.g., In re Meyers, 616 F.3d 626, 628 (7th Cir. 2010) (characterizing the Segal standard as a "background rule under the old Bankruptcy Act, to which courts still refer in the era of the Bankruptcy Code”); Andrews, 80 F.3d at 910-11 (applying the Segal standard to determine whether post-petition payments under a pre-petition non-compete agreement were property of the debtor’s estate); Ryerson, 739 F.2d at 1423 (concluding the Bankruptcy Code "follows Segal insofar as it includes after-acquired property 'sufficiently rooted in the prebankruptcy past’ but eliminates the requirement that it not be entangled with the debtor’s ability to make a fresh start”). But see Burgess v. Sikes (In re Burgess), 438 F.3d 493, 498 (5th Cir.2006) (en banc) (<HOLDING>). 13 . Although the parties frame the issue as 
 Holding statements: (A) holding that the eleventh amendment does not bar a bankruptcy court from issuing a money judgment against a state under the bankruptcy code (B) holding that bankruptcy court is without jurisdiction to control disposition of chapter 13 debtors property that is not property of the bankruptcy estate unless the property is related to the bankruptcy proceedings of the code (C) holding that the question of whether an interest is a claim for bankruptcy purposes is to be resolved by reference to the text history and purpose of the bankruptcy code (D) holding although congress has specifically approved of segals result segals sufficiently rooted test did not survive the enactment of the bankruptcy code footnote omitted (E) holding that the bankruptcy code endows the bankruptcy trustee with the exclusive right to sue on behalf of the estate
Example Output: holding that the eleventh amendment does not bar a bankruptcy court from issuing a money judgment against a state under the bankruptcy code

Example Input: 746 P.2d 270 (Utah Ct.App.1987); see also State v. Bakalov, 1999 UT 45, ¶ 20, 979 P.2d 799. Although we have cautioned against saddling defendants with a choice between ineffective counsel and no counsel at all, that is not the case presented here. As we have noted above, supra ¶¶ 15-17, Waterfield has not demonstrated that good cause — such as a conflict of interest, a complete breakdown in communication or an irreconcilable conflict — existed for substitution of counsel. Moreover, prior to the denial of substitute counsel, Waterfield had made two requests to proceed pro se and had informed the court that he was prepared to do so. On this record, we conclude that the district court could find that Waterfield’s waiver was voluntary. See Bakalov, 1999 UT 45, ¶ 20, 979 P.2d 799 (<HOLDING>). ¶ 28 The colloquy conducted by the district 
 Holding statements: (A) holding defendants pro se motion to reduce sentence was not properly before the trial court when defendant was represented by counsel since defendant may not proceed both by counsel and pro se (B) holding waiver of right to counsel at sentencing not voluntary when trial court tried to dissuade discharge of counsel defendant believed incompetent for the waiver to be voluntary the trial court must inquire into the reasons for the defendants dissatisfaction with his counsel to ensure that the defendant is not exercising a choice between incompetent or unprepared counsel and appearing pro se (C) holding that a defendants decision to proceed pro se was voluntary despite having to choose between that course and proceeding with counsel with whom he had expressed dissatisfaction because the defendant had not shown good cause for substitution of counsel (D) holding that a defendant has a right to proceed pro se at trial (E) holding that a defendants waiver was invalid where he was required to choose between proceeding with unprepared counsel or no counsel
Example Output:
holding defendants pro se motion to reduce sentence was not properly before the trial court when defendant was represented by counsel since defendant may not proceed both by counsel and pro se