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: Discipl. LEXIS 78, *9 (attorney disbursed all settlement proceeds to client less amount he retained for himself, after having been placed on notice that prior attorney claimed an in terest in any settlement funds in violation of Colo, RPC 1.15(b)). III. ANALYSIS OF SANCTION In both the Dunn and McCarthy matters, Rishel engaged in knowing conversion by obtaining funds from third parties for a stated purpose, failing to utilize the funds for that purpose, retaining the funds for an extended period of time after the third parties had withdrawn authorization, and failing to refund the amounts paid to the third parties despite their demand that he do so. The presumptive sanction for knowing conversion of the property of another is disbarment. People v. Dice, 947 P.2d 339, 340 (Colo.1997)(<HOLDING>); Motsenbocker; 926 P.2d at 577 (attorney 
 Holding statements: (A) holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause (B) holding that a lawyers knowing misappropriation of funds whether belonging to a client or third party warrants disbarment except in the presence of extraordinary factors of mitigation (C) holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors the attorneys clients did not suffer actual harm and the attorney established several mitigating factors (D) holding that permanent disbarment was appropriate for failure to remit 2000 in settlement funds to client and failing to answer the charges (E) recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person
Example Output: holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause

Example Input: are reasonably susceptible to two different interpretations, and therefore are ambiguous. See Westchester Surplus Lines Ins. Co. v. Keller Transp., Inc., 382 Mont. 72, 365 P.3d 465, 470 (Mont. 2016). Montana law construes ambiguous provisions “against the insurer and in favor of extending coverage.” Id. We therefore reject United Fire’s argument that the Premises Endorsements limit coverage to incidents that occurred on the St. George premises. Because the Premises Endorsements purport to cover claims “arising out of ... the use of’ the St. George premises, they are sufficiently capacious to include coverage for bodily injury in Montana that flows from or grows out of the use of the St. George premises. See State Farm Mut. Auto. Ins. Co. v. Ferrin, 311 Mont. 155, 54 P.3d 21, 23 (2002) (<HOLDING>). Thus, United Fire had a duty to defend 
 Holding statements: (A) holding that an arising out of exclusion applies to claims flowing from or growing out of the excluded activity (B) holding that the phrase arising out of the use is ambiguous and interpreting it as originating from or growing out of or flowing from (C) holding that insurance provisions excluding damage arising out of the use of land motor vehicles subject to registration and damage arising out of the use of land motor vehicles if the injury or damage occurs away from the insured premises were ambiguous because together they could be read in four different ways (D) holding claim for injuries arising out of use of truck and not from negligent supervision excluded from coverage by auto exclusion in commercial general liability policy no claim that language in policy was ambiguous or unclear (E) holding phrase arising out of the ownership maintenance or use of a motor vehicle as contained in um policy should be given same interpretation as in automobile liability policies
Example Output: holding that an arising out of exclusion applies to claims flowing from or growing out of the excluded activity

Example Input: damage award in this case was fashioned for a compensatory purpose or that it is unconstitutionally disproportionate to the character of Travelers’ bad faith behavior or the award of compensatory damages. We also reject Grossi’s position that the trial court erred or abused its discretion in awarding interest on the $300,000.00 UIM claim, rather than the entire arbitration award. We, however, agree with Travelers that the trial court erred as a matter of law in awarding Gros-si’s expert witness fee expenses as recoverable costs under section 8371. Accordingly, we direct the trial court to mold the costs portion of its verdict to reflect an award of $2,729.66. In all other respects the trial court’s verdict and judgment is affirmed. Judgment affirmed in part and vacated in p 002) (<HOLDING>). We do so here. 2 . A loss reserve is an 
 Holding statements: (A) holding appeal from order denying posttrial motions was proper since prothonotary entered judgment prior to appellate disposition (B) holding that in the interest of judicial economy considering appeal from order denying posttrial motions and ordering entry of judgment in favor of plaintiff even though judgment was not actually entered (C) holding that although an order dismissing appellants motion for posttrial relief was not reduced to judgment in the interests of judicial economy the supreme court could regard as done that which ought to have been done and proceed with the appeal (D) holding that the trial courts written order was not the entry of a sentence sufficient to support a determination that a judgment of conviction was entered (E) holding premature notice of appeal was treated as entered on date of entry of final judgment
Example Output:
holding appeal from order denying posttrial motions was proper since prothonotary entered judgment prior to appellate disposition