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.

[Q]: 879 (citations omitted). We think there is a reasonable fit here between the State’s purpose of protecting society from persons who have been determined to be likely to reoffend if not placed in a secure facility and their placement in such a facility. Therefore, Garren has failed to show a substantive due process violation. VII. Vagueness. Although Garren states in a division heading in his brief that chapter 229A is vague as applied and on its face, he makes no argument in his brief in support of the contention that the statute is vague as applied to him. We deem this issue waived. See Iowa R.App.P. 14(a)(3) (“Failure in the brief to state, to argue or to cite to authority in support of an issue may be deemed waiver of that issue.”); State v. Cooley, 608 N.W.2d 9, 13-14 (Iowa 2000) (<HOLDING>). Consequently, Garren is precluded from 
 Holding statements: (A) holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief (B) holding issue waived where matter not addressed beyond reference in heading in brief (C) holding that an issue mentioned in a brief but not addressed is waived (D) holding issues argued orally but not addressed in brief were waived (E) holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned
[A]: holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief


[Q]: CURIAM. Anthony McLemore was tried by jury and convicted of possession of cocaine and possession of cannabis. We agree with McLemore that the trial court erred in failing to give the jury his requested special instruction that an element of the crime is knowledge by the defendant that the substances possessed were marijuana and cocaine. See Chicone v. State, 684 So.2d 736, 746 (Fla.1996). Even though McLemore disavowed any connection whatsoever to the items, we find that the error was not harmless. See Scott v. State, 808 So.2d 166 (Fla.2002)(<HOLDING>). Accordingly, we reverse the convictions and 
 Holding statements: (A) holding that failure to give proper instruction regarding disputed element of crime charged was fundamental error requiring reversal and stating that fundamental error is not subject to harmless error review (B) holdingthat because the evidence of the defendants guilt was overwhelming the courts failure to give a requested charge on impeachment constituted harmless error (C) holding that a trial court errs when it fails to give a limiting instruction properly requested by a party (D) holding that failure to give a limiting instruction for 404b evidence is not plain error (E) holding that failure to give a properly requested chicone instruction cannot be harmless error
[A]: holding that failure to give proper instruction regarding disputed element of crime charged was fundamental error requiring reversal and stating that fundamental error is not subject to harmless error review


[Q]: 578 (finding purposeful availment because of foreign corporation’s “additional conduct through which it aimed to get extensive business in or from this state”). Indeed, specific jurisdiction over foreign manufacturers is often premised on sales by independent distributors. See, e.g., Bridgeport Music, Inc. v. Still N The Water Publ’g, 327 F.3d 472, 483-84 (6th Cir.2003) (finding specific jurisdiction under “additional conduct” standard based in part on nationwide distribution agreement with independent distributor); Kuenzle v. HTM Sport-Und Freizeitgerate AG, 102 F.3d 453, 458 (10th Cir.1996) (noting that “[t]he actions of an independent distributor may not insulate a foreign company from specific jurisdiction”); Tobin v. Astra Pharm. Prods., Inc., 993 F.2d 528, 533-34 (6th Cir.1993) (<HOLDING>); see also Pennzoil Prods. Co. v. Colelli & 
 Holding statements: (A) holding that the exercise of personal jurisdiction over a nonresident auto distributor whose only connection to the forum resulted from a customers decision to drive there failed to provide the defendant with clear notice that it would be subject to suit in the forum state and thus an opportunity to alleviate the risk of burden some litigation there (B) holding that personal jurisdiction over defendant car manufacturer was inappropriate when defendants only contacts with the forum resulted from plaintiffs unilateral activity of driving defendants product into another state (C) holding that foreign drag manufacturer who marketed its product in kentucky through independent distributor was nonetheless subject to personal jurisdiction in forum under asahis additional conduct standard (D) holding defendant a foreign manufacturer was not subject to the personal jurisdiction of a wyoming court because the plaintiff failed to introduce sufficient evidence to establish an agency relationship between the defendant and its us distributor (E) holding consumers unilateral act of taking product to forum state insufficient to subject manufacturer to jurisdiction there
[A]:
holding that the exercise of personal jurisdiction over a nonresident auto distributor whose only connection to the forum resulted from a customers decision to drive there failed to provide the defendant with clear notice that it would be subject to suit in the forum state and thus an opportunity to alleviate the risk of burden some litigation there