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.

[EX Q]: judicial review of an arbitration award. See UHC Management Co., 148 F.3d at 998 (“ “We may not set an award aside simply because ... the arbitrators erred in interpreting the law or in determining the facts.’ ”) (quoting Stroh Container Co., 783 F.2d at 751). This third challenge is nonetheless partially cognizable, but only to the extent it can be read as an assertion that there was evident partiality or corruption in the arbitrators, a statutory ground under 9 U.S.C. § 10(a)(2), as a claim of misconduct by the arbitrators in refusing to hear evidence or to provide a reasonable opportunity to present evidence, another statutory ground under 9 U.S.C. § 10(a)(3), or as an extra-statutory challenge to the “fundamental fairness” of the proceedings. See P & P Indus., Inc., 179 F.3d at 870 (<HOLDING>). Hoffman’s fourth challenge is to the denial 
 Holding statements: (A) recognizing such a ground for judicial review of arbitration awards in this circuit (B) holding right to be fundamental (C) holding that section 34810 is an adequate and independent state ground (D) recognizing plain or fundamental error (E) recognizing review for fundamental unfairness of the proceedings as an independent extrastatutory ground
[EX A]: recognizing such a ground for judicial review of arbitration awards in this circuit

[EX Q]: ” Boone v. Commonwealth, 14 Va.App. 130, 133, 415 S.E.2d 250, 251 (1992). “A battery is an unlawful touching of another.... Whether a touching is a battery depends on the intent of the actor, not on the force applied.” Adams v. Commonwealth, 33 Va.App. 463, 468-69, 534 S.E.2d 347, 350 (2000) (citation omitted). “ ‘[T]he slightest touching of another ... if done in a rude, insolent, or angry manner, constitutes a battery for which the law affords redress.’ ” Id. at 469, 534 S.E.2d at 350 (citation omitted). Accordingly, where Vaughn claims he only intended to scare Robinson and did not intend to shoot or wound him, Vaughn would not be entitled, in my opinion, to have the jury instructed on assault and battery. See Wynn v. Commonwealth, 5 Va.App. 283, 292, 362 S.E.2d 193, 198 (1987) (<HOLDING>). A second theory supported by the evidence is 
 Holding statements: (A) holding that shooting at a person intending only to scare the person where no touching or wounding occurs supports instructing the jury on simple assault (B) holding that simple assault includes urinating on another (C) holding with no analysis that any person or organization who may be legally liable therefor applies to a person legally liable for injuries caused by an accident   4 when under the facts of the case the only person to whom the clause could have applied was a tortfeasor (D) holding that punching another person is a statutory assault (E) holding simple assault is a lesser included offense of recklessly endangering another person
[EX A]: holding that simple assault includes urinating on another

[EX Q]: consistent with innocent conduct and showed “no indicia of criminal activity.” We find, however, that, taken together as a whole, Alston’s actions after he drove by the patrol car were sufficiently suspicious to provide Hixson with the requisite reasonable and articulable suspicion to stop Alston from walking away from the scene. See Terry, 392 U.S. at 22-23, 88 S.Ct. at 1880-81 (concluding that defendant’s “series of acts, each of them perhaps innocent in itself,” in combination warranted further investigation by the police). Hixson’s brief detention of Alston was therefore reasonable to allow the officer to confirm or dispel his suspicion and to maintain the status quo during the course of the lawful roadside investigatory stop. See Hatcher, 14 Va.App. at 491-92, 419 S.E.2d at 259 (<HOLDING>); see also United States v. Mancillas, 183 F.3d 
 Holding statements: (A) holding that a police officers brief detention of a passenger who walked away from a lawfully stopped vehicle is warranted to promote the officers significant interest in gaining control of and monitoring a potentially hazardous roadside stop in order to conduct his lawful investigation particularly when events subsequent to the lawful traffic stop focus suspicion on the passenger (B) holding that fourth amendment rights of a passenger of a legally stopped vehicle were not violated by police officers instruction that he remain inside the vehicle during traffic stop after passenger repeatedly tried to exit (C) holding police officers making a traffic stop could order passengers out of the stopped car (D) holding that an officer may order a passenger out of a vehicle during a stop for a traffic infraction (E) holding that police officer was not justified in detaining a passenger who exited and began to walk away from a lawfully stopped vehicle absent an articulated reason as to why it was necessary to detain the passenger for the officers safety
[EX A]:
holding that fourth amendment rights of a passenger of a legally stopped vehicle were not violated by police officers instruction that he remain inside the vehicle during traffic stop after passenger repeatedly tried to exit