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: ... shall exist within the United States,” U.S. Const, amend. XIII, § 1, and empowers Congress to enforce its provisions, see U.S. Const, amend. XIII, § 2. The Supreme Court has interpreted this grant of power broadly, finding that Congress can affirmatively enforce the ban on slavery and involuntary servitude, and enact legislation to erase “all badges and incidents of slavery in the United States.” Civil Rights Cases, 109 U.S. 3, 20, 3 S.Ct. 18, 27 L.Ed. 835 (1883). Moreover, in Jones v. Alfred H. Mayer Co., 392 U.S. 409, 88 S.Ct. 2186, 20 L.Ed.2d 1189 (1968), the Supreme Court opened the door to the inclusion of private acts of racial discrimination within the “badges and incidents of slavery” language as stated in the Civil Rights Cases. See Jones, 392 U.S. at 413, 88 S.Ct. 2186 (<HOLDING>). Although the Thirteenth Amendment was 
 Holding statements: (A) holding that 42 usc  1982 a provision of the civil rights act of 1866 which allows victims of racial discrimination to sue private defendants was a valid exercise of congress thirteenth amendment authority (B) holding official immunity is available in claims of discrimination if plaintiff fails to establish his treatment by defendants was so at variance with what would reasonably be anticipated absent racial discrimination that racial discrimination is the probable explanation (C) holding that civil rights claims under 42 usc  1981 and 1982 are personal injury tort claims (D) holding that the retaliation provision of title vii is an adequate exercise of congress authority under section 5 of the fourteenth amendment (E) holding that 18 usc  245 a statute passed on the same day as 42 usc  3631 and for similar purposes constituted a valid enactment under congress thirteenth amendment authority as applied to racially motivated interference with federallyprotected rights
Example Output: holding official immunity is available in claims of discrimination if plaintiff fails to establish his treatment by defendants was so at variance with what would reasonably be anticipated absent racial discrimination that racial discrimination is the probable explanation

Example Input: § 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the § 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA’s one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this § 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, — U.S. -, 121 S.Ct. 78, 148 
 Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
Example Output: holding that issues not raised before the district court cannot be raised for the first time before this court

Example Input: not be addressed. Y. Conclusion The trial court did not err in identifying, valuing, or dividing the parties’ property. Those portions of the judgment are affirmed. The record is insufficient for this court to determine whether Wife’s income-producing property is adequate to meet her reasonable needs. Therefore, the maintenance order is reversed, and the cause is remanded to the trial court to reconsider the maintenance issue. All concur. 1 . All statutory references are to the Revised Statutes of Missouri 2000. 2 . Generally, income tax is not owed on an inheritance. In this case, however, the parties’ 1992 joint income tax return designated Wife's inheritance of $685,285 as income from IRA distributions, and income tax was paid on it. 3 . Husband cites Beckham, 41 S.W.3d at 912-14 (<HOLDING>); Cuda v. Cuda, 906 S.W.2d 757, 759 
 Holding statements: (A) holding that home purchased with spouses separate funds prior to marriage was transmuted into marital property because mortgage payments made from joint account home was used as marital residence and both parties devoted resources and energy into home (B) holding that furniture and furnishings for marital residence purchased with separate funds were transmuted into marital property because they were acquired and treated as communal property (C) holding that home purchased with separate funds and titled in one spouses name was transmuted into marital property because home was used as marital residence and the other spouse contributed to payments and repairs on home (D) holding that separate property valued at 45000 was transmuted to marital property when improved by 3800 of marital property (E) holding that the lower court failed to account for payments made in connection with the marital home including mortgage payments
Example Output:
holding that furniture and furnishings for marital residence purchased with separate funds were transmuted into marital property because they were acquired and treated as communal property