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: States Dist. Court, 407 U.S. 297, 313, 92 S.Ct. 2125, 32 L.Ed.2d 752 (1972). The Supreme Court has recognized that “searches and seizures inside a home without a warrant are presumptively unreasonable.” Payton v. New York, 445 U.S. 573, 586, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980). However, the Supreme Court has permitted exceptions to the warrant requirement when “special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement impracticable.” New Jersey v. T.L.O., 469 U.S. 325, 351, 105 S.Ct. 733, 83 L.Ed.2d 720 (1985) (Blackmun, J., concurring in judgment) (allowing school officials to conduct warrantless searches of student property without probable cause); see also O’Connor v. Ortega, 480 U.S. 709, 107 S.Ct. 1492, 94 L.Ed.2d 714 (1987) (<HOLDING>); Griffin v. Wisconsin, 483 U.S. 868, 873-74, 
 Holding statements: (A) holding searches conducted without a warrant based on probable cause are presumptively unreasonable (B) holding neither the warrant requirement nor the probable cause requirement should apply to noninvestigatory workrelated purposes or for investigations of workrelated misconduct  (C) holding a person may consent to warrantless searches as a condition of a suspended sentence (D) holding  1983 action lies for warrantless arrest without probable cause (E) holding that government employers may conduct warrantless workrelated searches of employees offices without probable cause
Example Output: holding searches conducted without a warrant based on probable cause are presumptively unreasonable

Example Input: the report and recommendation did not notify the parties that they must file timely objections to preserve their right to appellate review. He argues that the firm waiver rule should not be enforced in the absence of such an explicit notification. While we have held that the firm waiver rule is inapplicable when pro se litigants are not given explicit notice of the rule, see id. at 659, we have never extended that practice to counseled cases. We decline to do so today, because we expect counsel to know the rules. See Nasious v. Two Unknown B.I.C.E. Agents, 492 F.3d 1158, 1163 n. 5 (10th Cir.2007) (“[W]e expect counsel to know the pleading rules of the road without being given personal notice of them by the district court.”); United States v. Windrix, 405 F.3d 1146, 1157 (10th Cir.2005) (<HOLDING>). While 28 U.S.C. § 636(b)(1) provides that a 
 Holding statements: (A) holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules (B) holding that a criminal defendants counsel is charged with knowledge of the local criminal rules in their entirety including those parts of the local civil rules incorporated by reference (C) holding the district court did not abuse its discretion in applying its own local rules even though those rules prevented it from considering some facts improperly alleged by plaintiffs that might have been relevant to the summary judgment motion (D) holding that the federal expert witness compensation rules are in direct conflict with the state rules even when the state rules allow for a greater recovery (E) holding that defendants have a right to counsel in criminal proceedings
Example Output: holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules

Example Input: David K. Lewis, a California state prisoner, appeals pro se from the district court’s summary judgment for defendants in his 42 U.S.C. § 1983 action alleging that his due process rights were violated in connection with the confiscation of a television set. We have jurisdiction under 28 U.S.C. § 1291. We review de novo. Hawkins v. Risley, 984 F.2d 321, 323 (9th Cir.1993) (per curiam). We affirm. The district court properly granted summary judgment based on the doctrine of issue preclusion because Lewis’s due process claims were previously litigated and decided on the merits in a state habeas proceeding. See In re Lewis, 03W0051B, slip op. at 1-2 (Cal.Super.Ct. March 12, 2004); Silverton v. Dep’t of Treasury, 644 F.2d 1341, 1347 (9th Cir.1981) (<HOLDING>). The district court did not abuse its 
 Holding statements: (A) holding issue preclusion bars section 1983 plaintiff from relitigating fourth amendment issue decided in state court criminal proceeding (B) holding that aedpa limits a federal habeas court to the record before the state court where a claim has been adjudicated on the merits by the state court (C) holding that a habeas claim is procedurally barred where it was already raised on direct appeal and decided on the merits by this court (D) holding that the federal habeas corpus court could reach the merits of a due process claim even though there was no contemporaneous objection in state court trial where the state habeas corpus court reached the merits rather than rely on the procedural default defense (E) holding that a state habeas proceeding decided on the merits precluded a section 1983 action in federal court
Example Output:
holding issue preclusion bars section 1983 plaintiff from relitigating fourth amendment issue decided in state court criminal proceeding