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: § 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the § 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA’s one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this § 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, — U.S. -, 121 S.Ct. 78, 148 
 Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
Example Output: holding that issues not raised before the district court cannot be raised for the first time before this court

Example Input: to allege damages through June 30, 2006 is the focus of their motion.”). Because the Government does not oppose Plaintiff supplementing the September 4, 2009 Complaint to seek damages through the end of 2009, the issue before the court is whether Plaintiff may supplement to allege a claim for damages incurred through December 31, 2009, or through December 31, 2010. See System Fuels, 73 Fed.Cl. at 211 (“Supplementation may be limited or curtailed to avoid prejudice.” (citation omitted)). Although Plaintiff may have given the Government an estimate of 2010 damages as early as July 2010, Plaintiff did not identify the specific 2010 damages claimed or provide the Government with supporting documentation of those damages until April 20, 2011 — t 4 Fed.Cl. 727 (2006) (“SMUD III") (<HOLDING>), aff'd in part, rev'd in part, 293 Fed.Appx. 
 Holding statements: (A) holding that smud is entitled to 53159863 in mitigation costs but staying entry of judgment pending the outcome of this proceeding (B) holding that smud was entitled to 39796234 in damages (C) holding that a plaintiff is entitled to either statutory treble damages or punitive damages whichever is the greater (D) holding that plaintiff was not entitled to a presumption of nominal damages when she had failed to request them (E) holding that smud was entitled to mitigation damages for costs incurred from may 15 1997 to december 31 2003
Example Output: holding that smud is entitled to 53159863 in mitigation costs but staying entry of judgment pending the outcome of this proceeding

Example Input: bad faith breach of contract claim, it is clear that a state law bad faith cause of action against an ERISA provider is expressly preempted. In order to be characterized as a state law regulating insurance, the law must be “specifically directed toward that industry.” Pilot Life Ins. Co., 481 U.S. at 50, 107 S.Ct. 1549. Stated differently, the state law must “home[] in on the insurance industry.” Ward, 526 U.S. at 368, 119 S.Ct. 1380. The Iowa courts have not confined common law, bad faith causes of action to the insurance industry. Rather, it is a general law, applicable to the entire panoply of contracts. Accordingly, the plaintiffs’ common law bad faith cause of action is not saved from preemption by ERISA’s savings clause. See Pilot Life Ins. Co., 481 U.S. at 51, 107 S.Ct. 1549 (<HOLDING>), Kidneigh, 345 F.3d at 1186-87 (holding that 
 Holding statements: (A) holding that a bad faith claim is a tort (B) holding that improper motive is element of bad faith (C) holding that a state common law of bad faith was not integral to the insurerinsured relationship (D) holding title company liable for bad faith (E) holding that bad faith includes lack of good faith in investigating the facts of a complaint
Example Output:
holding that a bad faith claim is a tort