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: v. Valenzuela, 722 F.2d 1431, 1433 (9th Cir.1983) (requiring the defendant to shave); United States v. Lamb, 575 F.2d 1310, 1316 (10th Cir.1978) (same); United States v. Murray, 523 F.2d 489, 492 (8th Cir.1975) (requiring the defendant to wear a wig); United States v. Roberts, 481 F.2d 892, 894 (5th Cir.1973) (requiring the defendant to put on a stocking mask worn during the robbery). If a defendant who is compelled to don clothing before the jury does not “testify” for purposes of the Self-Incrimination Clause, it would seem to follow, a fortiori,' that the Self-Incrimination Clause also provides that a defendant who voluntarily dons clothing before the jury may not be required to subject himself to cross-examination. See United States v. Bay, 762 F.2d 1314, 1315-16 (9th Cir.1985) (<HOLDING>). We therefore conclude that a physical 
 Holding statements: (A) holding that district court did not err in concluding after an evidentiary hearing that the immunity agreement between defendant and the government did not extend to the charge being prosecuted (B) holding that the district court correctly declined to instruct the jury that the government was required to prove as an element of the offense that the defendant did not intend to establish a life with his wife (C) holding that a district court did not err in concluding that the defendant was not entitled to a downward departure due to his status as an alien subject to removal (D) holding that the district court erred in concluding that a defendant was required to take the stand to display his tattoos because the government may compel a defendant to display such physical characteristics (E) holding the government must demonstrate the defendant knew of the characteristics of the firearm that required it to be registered
Example Output: holding that district court did not err in concluding after an evidentiary hearing that the immunity agreement between defendant and the government did not extend to the charge being prosecuted

Example Input: pain and suffering, demonstrated his reliance on a prohibited tort theory); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242-43 (1988) (declining to consider an intentional infliction of emotional distress action, in which the plaintiff sought damages for “anguish, shock, nervousness, and depression,” because the abolition of claims for alienation of affections was intended to preclude these allegations); see also Wilson v. Still, 819 P.2d 714, 716 (Okla.1991) (finding a suit for intentional infliction of emotional distress was barred because the plaintiff basically sued the defendant for “wil-fully taking away her husband” and stating the legislature immunized that conduct from tort liability). But see Erickson v. Christenson, 99 Or.App. 104, 781 P.2d 383, 385-86 (1989) (<HOLDING>), appeal dismissed, 311 Or. 266, 817 P.2d 758 
 Holding statements: (A) holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute (B) holding a plaintiff could proceed on a claim alleging intentional infliction of emotional distress because the alleged losses were different from those for seduction but also stating plaintiffs previously suing for seduction could recover for damage to character and reputation as well as for mental anguish and pecuniary losses (C) recognizing validity of cause of action for intentional infliction of emotional distress (D) holding that police officers were immune from liability for damages resulting from alleged intentional infliction of emotional distress (E) recognizing the tort of intentional infliction of emotional distress
Example Output: holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute

Example Input: that placed Wolfe on the vexatious litigant list and imposed a prefiling order against him. In response, Wolfe states that he referred to these' prior events in his complaint in order to demonstrate his standing to pursue his constitutional challenge. For Wolfe to have standing to challenge the Vexatious Litigant Statute, he must show that he is sufficiently likely to be injured by the operation of the statute that his dispute is ripe. One way — often the best way — for a plaintiff to establish standing in such a case is to demonstrate that he has previously engaged in the sort of activity in which -he now claims' he will engage again if not prohibited by the statute he seeks to challenge. See United Public Workers v. Mitchell, 330 U.S. 75, 89-92, 67 S.Ct. 556, 91 L.Ed. 754 (1947) (<HOLDING>). One can also establish standing to sue by 
 Holding statements: (A) holding that plaintiffs lacked standing to sue (B) holding that persecution was on account of political opinion because petitioners prosecutorial investigation into acts of political corruption was by its very nature political (C) holding attorney lacked standing to challenge amount of attorney fees awarded plaintiffs not parties to the appeal (D) holding that plaintiffs lacked standing because the case was not ripe for adjudication (E) holding that plaintiffs lacked standing to challenge the hatch act because the nature of the political activities they intended to engage in was a matter of speculation
Example Output:
holding that plaintiffs lacked standing to sue