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: in the record of any possible medical treatment that Monroe County or the individual defendants could have provided to save the life of the Decedent. Phillips argues in her brief that it is not necessary for her to prove chemotherapy would have saved the Decedent’s life. First, she refers to the fright and anxiety both she and the Decedent suffered because of the delay in chemotherapy. In this regard, Phillips confuses the causation issue. In a survival action, damages for the Decedent’s physical suffering and mental anxiety as a result of the alleged deprivation of medical care would have been appropriate. In a wrongful death context, however, no damages are available until the plaintiff has cleared the causation hurdle. See Wilks v. Am. Tobacco Co., 680 So.2d 839, 842 (Miss.1996) (<HOLDING>). Second, Phillips suggests that she need only 
 Holding statements: (A) recognizing cause of action for wrongful death (B) holding that plaintiffs failure to prove decedents death was caused by the wrongful acts of the defendant precludes any recovery of wrongful death damages under mississippis wrongful death statute (C) holding unconstitutional a state wrongful death statute which denied illegitimate children the right to recover for the wrongful death of their mother (D) holding that a failure to include a beneficiary in a wrongful death action is a defect because the wrongful death act restricts plaintiffs to a single action (E) holding that mississippis wrongful death statute creates an independent cause of action

Output: recognizing cause of action for wrongful death


Input: Consider Input: Majority Opinion in Ford, former Justice Newman authored a concurring opinion, which Justice Saylor joined, in which she specifically expressed her agreement “that appellate counsel acted ineffectively by neglecting to raise trial counsel's ineffectiveness for failing to investigate and present evidence during the penalty phase of Appellant’s history of abuse and mental illness.” Ford, 809 A.2d at 336 (Newman, J., joined by Saylor, J., concurring). 5 . Although Teague's retroactivity analysis did not gamer five votes, a majority of the High Court soon thereafter reaffirmed the Teague plurality's rule and its two exceptions in Penry v. Lynaugh, 492 U.S. 302, 313, 109 S.Ct. 2934, 106 L.Ed.2d 256 (1989). 6 . Compare with Roper v. Simmons, 543 U.S. 551, 125 S.Ct. 1183, 161 L.Ed.2d 1 (2005) (<HOLDING>); Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 
 Holding statements: (A) holding that leaning towards the death penalty is not the same as an automatic vote for the death penalty (B) holding that mentally retarded capital murderers are constitutionally ineligible for death penalty (C) holding that juveniles are constitutionally ineligible for death penalty (D) holding that defendant may be subject to death penalty on resentencing (E) holding that the death penalty is unconstitutional as applied to juvenile defendants

Output: holding that leaning towards the death penalty is not the same as an automatic vote for the death penalty


Input: Consider Input: over the area in common with a co-occupant who later objects to the use of evidence so obtained.” Id. at 1518. The Court, however, also held that, as between a wife’s consent to a search of the family residence and her husband’s refusal to consent, "a physically present co-occupant’s stated refusal to permit entry prevails, rendering the warrantless search unreasonable and invalid as to him.” Id. at 1519. Comments, Model Civ. Jury Instr. 9th Cir. 9.13 (2007). 13 . See also Cal. Penal Code § 3067(d) (in the context of parole searches, noting "[i]t is not the intent of the Legislature to authorize law enforcement officers to conduct searches for the sole purpose of harassment.”). 14 . But see Owen v. City of Independence, 445 U.S. 622, 650-52, 657, 100 S.Ct. 1398, 63 L.Ed.2d 673 (1980) (<HOLDING>); see also Gibson v. Cty. of Washoe, Nev., 290 
 Holding statements: (A) holding that defendants are not entitled to qualified immunity (B) holding immunity from liability is not jurisdictional (C) recognizing a claim for civil liability against municipalities  under  1983 (D) holding individual officers entitlement to qualified immunity does not immunize municipalities from monell liability (E) holding that qualified immunity is not merely immunity from damages but also immunity from suit


Output: holding that defendants are not entitled to qualified immunity