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: unlawful harm under that public policy may include actions that violate recognized and accepted standards of conduct, such as applicable codes of ethics. The critical question in this case is whether under all of the surrounding circumstances MacDougall’s termination by Weiehert violated that clear mandate of public policy and was in retaliation for either his vote on the municipal parking ban ordinance or his refusal to change the ordinance. At the outset, we recognize that conduct that is directed against constitutionally-protected activity may violate a clear mandate of public policy, even though it may not offend any other statutory or legal standard. Supra at 390, 393, 677 A.2d at 167, 168. Compare Shovelin v. Central New Mexico Elec. Coop., Inc., 115 N.M. 293, 850 P.2d 996 (1993) (<HOLDING>) with Novosel v. Nationwide Ins. Co., 721 F.2d 
 Holding statements: (A) holding that employees retaliatory discharge based on employees election to public office did not violate public policy (B) recognizing public policy limits on employer discretion in discharging employees (C) holding public employees conduct and expression in internal investigation of employees at county prosecutors office to expose potential wrongdoing constituted matter of public concern (D) recognizing retaliatory discharge claim where employer prevented employees exercise of workers compensation rights because of employees intention to file claim (E) holding that the discharge of an employee hospitalized for illness did not violate public policy
Example Output: recognizing public policy limits on employer discretion in discharging employees

Example Input: of the evidence to have determined the outcome.” Id.; accord Snow v. State, 697 S.W.2d 663, 666-68 (Tex.App.-Houston [1st Dist.] 1985), pet. dism’d, 794 S.W.2d 371 (Tex.Crim.App.1987). A “single egregious error” may constitute ineffective assistance. Thompson, 9 S.W.3d at 813. Frequently, it has. Texas Cases Reversing Without Evidence of Trial Strategy In at least 22 cases decided after the Court of Criminal Appeals decided Jackson v. State, Texas courts have reversed even though no evidence of trial counsel’s reasoning was presented. See Woods v. State, 59 S.W.3d 833, 835-38 (Tex.App.-Texarkana 2001, pet. filed); Mares v. State, 52 S.W.3d 886, 893 (Tex.App.-San Antonio 2001, pet. ref'd); Jaubert v. State, 65 S.W.3d 73 (Tex.App.-Waco 2000, pet. granted) (designated for publication) (<HOLDING>); Robison v. State, 35 S.W.3d 257, 265 
 Holding statements: (A) recognizing rule (B) recognizing a limited exception to the eightcorners rule for a pure coverage question where the insurer is not questioning the merits of the underlying thirdparty claim and the extrinsic evidence goes strictly to an issue of coverage without contradicting any allegation in the thirdparty claimants pleadings material to the merits of that underlying claim (C) recognizing that sanctions are collateral to the merits of the case and may be considered even after the merits are no longer before the district court (D) holding that procedural bar rule does not apply to ineffectiveness claims (E) recognizing the rule in robinson and reviewing the merits of ineffectiveness claim without evidence of trial counsels strategy
Example Output: recognizing rule

Example Input: Union, Local 535, Serv. Emps. Int'l Union, AFL-CIO v. Cnty. of Santa Clara, 609 F.2d 944, 949 (9th Cir.1979). The Court considers Defendants’ arguments with respect to Edwards and her counsel separately. a. The Adequacy of Edwards as Named Plaintiff Defendants’ argument that Edwards is inadequate is primarily based on Edwards’s testimony in an unrelated bankruptcy proceeding. Rule 23(a)(4) requires that “the representative parties fairly and adequately protect the interests of the class.” Fed.R.Civ.P. 23(a)(4). This requirement ensures that the named plaintiff and his or her counsel will pursue each class member’s claim with sufficient “vigor.” Hanlon v. Chrysler Corp., 150 F.3d 1011, 1021 (9th Cir.1998); see also Crawford v. Honig, 37 F.3d 485, 487 (9th Cir.1994) (citations omitted) (<HOLDING>). As previously stated by this Court, however, 
 Holding statements: (A) holding that a class representatives ignorance of the case is not a bar to certification unless it impairs the representatives ability to vigorously prosecute the action (B) holding that the fair and adequate representation requirement was not satisfied because of litigation between plaintiff and defendant the antagonism between the parties and the lack of support plaintiff garnered in its claim (C) holding that ajdequate representation depends on the qualifications of counsel for the representatives an absence of antagonism a sharing of interests between representatives and absentees and the unlikelihood that the suit is collusive (D) recognizing that the number of class representatives is not significant under rule 23a (E) holding that awards of 2500 to majority of representatives and 5000 to deposed representatives were inappropriate where representatives had borne little risk by participating in litigation and provided services that could have been provided by any other class member
Example Output:
holding that a class representatives ignorance of the case is not a bar to certification unless it impairs the representatives ability to vigorously prosecute the action