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.

[Q]: for a damages claim. See Williams, 216 S.W.3d at 828-29. Nor can Russell change the facts that render her remaining grounds not justiciable. As long as there is no dispute that the release between Metro and American Century is not binding on Russell, and Metro and its representatives have not been awarded and do not seek attorney fees based on section 417.003 of the Labor Code, there is no way in which Russell could re-plead her claims to confer jurisdiction on the trial court. See Bonham State Bank, 907 S.W.2d at 467; WesternGeco, L.L.C., 246 S.W.3d at 781. The trial court therefore did not err in refusing Russell an opportunity to further amend her pleadings. For the foregoing reasons, we affirm the trial court’s judgment. 1 . S rters, Inc., 372 S.W.2d 525, 530-31 (Tex.1963) (<HOLDING>); Cobb v. Harrington, 144 Tex. 360, 366, 190 
 Holding statements: (A) holding governmental immunity was not implicated in a declaratoryjudgment action seeking an interpretation of a competitive bidding statute as applied to the highway commissions policy of requiring all materials furnished under contracts be manufactured in the united states (B) holding that a declaratoryjudgment action seeking to compel officials to perform their legal duties was not barred by  14 however a portion of the action seeking compensatory damages could not be maintained (C) holding a declaratoryjudgment action was proper to construe compulsory school attendance law and did not implicate governmental immunity (D) holding governmental immunity not implicated and a declaratoryjudgment action proper to seek determination of whether plaintiffs were motor carriers for purposes of tax statute (E) recognizing the protection of preliminary governmental materials
[A]: holding that a declaratoryjudgment action seeking to compel officials to perform their legal duties was not barred by  14 however a portion of the action seeking compensatory damages could not be maintained


[Q]: 879 (citations omitted). We think there is a reasonable fit here between the State’s purpose of protecting society from persons who have been determined to be likely to reoffend if not placed in a secure facility and their placement in such a facility. Therefore, Garren has failed to show a substantive due process violation. VII. Vagueness. Although Garren states in a division heading in his brief that chapter 229A is vague as applied and on its face, he makes no argument in his brief in support of the contention that the statute is vague as applied to him. We deem this issue waived. See Iowa R.App.P. 14(a)(3) (“Failure in the brief to state, to argue or to cite to authority in support of an issue may be deemed waiver of that issue.”); State v. Cooley, 608 N.W.2d 9, 13-14 (Iowa 2000) (<HOLDING>). Consequently, Garren is precluded from 
 Holding statements: (A) holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief (B) holding issue waived where matter not addressed beyond reference in heading in brief (C) holding that an issue mentioned in a brief but not addressed is waived (D) holding issues argued orally but not addressed in brief were waived (E) holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned
[A]: holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief


[Q]: and (3) resulting injury of the other party. See In re FirstMerit Bank, N.A, 52 S.W.3d 749, 758 (Tex.2001). Fraud and fraudulent inducement are separate causes of action that share the same elements. See id.; see also Haase v. Glazner, 62 S.W.3d 795, 798 (Tex.2001). Hoagland alleged in his live petition, in relevant part, that each appellee “made written and oral misrepresentations of material fact to [Hoagland] ... in Harris County, Texas ... via email and telephone conversations and in-person meetings ... with the intention that [Hoagland] would rely upon such misrepresentations and take action or refrain from taking certain actions within Harris County, Texas.” (Emphasis added.) Hoagland Holding, LLC, 324 S.W.3d 840, 847 (Tex.App.Houston [14th Dist.] 2010, no pet.) (<HOLDING>). Accordingly, Hoagland pleaded allegations 
 Holding statements: (A) holding misrepresentation made by outofstate defendant to texas plaintiff who relied on it in texas satisfied requirement for jurisdiction under longarm statute based on commission of a tort in part in texas (B) holding plaintiffs allegation that defendants committed torts in texas was sufficient to bring defendants under the longarm statute (C) holding plaintiffs allegation that defendants committed torts in houston texas was sufficient to bring defendants under the longarm statute for plaintiffs claims of various forms of fraud and negligent misrepresentation (D) recognizing strong interest in protecting texas citizens where tort was committed in whole or in part in texas (E) holding plaintiff was required to allege defendants committed fraudulent acts in texas to satisfy his initial burden of pleading jurisdictional facts
[A]:
holding misrepresentation made by outofstate defendant to texas plaintiff who relied on it in texas satisfied requirement for jurisdiction under longarm statute based on commission of a tort in part in texas