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]: clause could be vitiated based on evidence of fraud “relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs’ allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 (“Fraud ... makes a contract voidable at the instance of the innocent party.”) (quoting 3 Corbin, Contracts, § 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs’ argument conflates their tort 
 Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable
[A]: holding that a contract made in violation of section 432070 is void rather than voidable


[Q]: transfer, and everything else about the transaction was local to St. Thomas, to wit: Franklin Martinez, the lender and president of Transcaribbean, is a St. Thomas resident and has substantial business interests in the Virgin Islands. Those interests include that Martinez is an officer and part-owner of Colombian Emeralds, Inc. and its subsidiaries, and a part-owner of Sea Wind Food Distributors, Inc., Clark asserts that federal jurisdiction is inappo-site because the transaction occurred between Martinez and Peter Clark — both local businessmen — and involved a loan to fund a local real-estate development. This argument fails because the Court may assume jurisdiction on the basis of a single interstate wire communication. See United States v. Pecora, 693 F.2d 421, 424 (5th Cir.1982) (<HOLDING>). Moreover, facts alleged by Clark about the 
 Holding statements: (A) holding that single substantial act can support exercise of personal jurisdiction (B) holding that the jurys guilty verdict on the separate substantive count of bribery under federal law confirms beyond any reasonable doubt that the jury would have convicted the defendant of honest services fraud if the courts definition had been limited to the bribery basis that skilling expressly approved (C) holding in action involving single claim that if claim sounded only in admiralty there would be no right to a jury trial but if federal question was present as a separate and independent basis for federal jurisdiction then the jury demand must be honored (D) holding that a federal court can assume jurisdiction over a local bribery ease involving only local residents on the basis of a single interstate telephone call (E) holding the federal tort claims act did not permit exercise of pendant jurisdiction over additional parties as to which no basis for federal jurisdiction existed
[A]: holding that single substantial act can support exercise of personal jurisdiction


[Q]: have been on notice regarding the ongoing thefts. Specifically, the amended complaint alleges that “Paul and Steven Mancuso informed FBI agents of the parking meter thefts between their guilty verdict on or about October 28, 2009 and the date set for sentencing on or about May 24, 2010.” See Dkt. No. 22 at ¶84. The amended complaint further alleges that “[t]he FBI questioned Ronald Mancuso in late November of 2009. On Wednesday, November 25, 2009, Ronald Mancuso confessed to the parking meter theft scheme.” See id. at ¶ 87. This passing reference to these events does not meet the high bar courts have set in order to recognize documents extraneous to the complaint as “incorporated by reference.” See Global Network Commc’ns, Inc. v. City of New York, 458 F.3d 150, 156 (2d Cir.2006) (<HOLDING>); Thomas v. Westchester County Health Care 
 Holding statements: (A) holding entry of guilty plea waives challenges to the deprivation of constitutional rights that occurred prior to the entry of the guilty plea  emphasis added (B) holding that a defendants guilty plea was unconditional where the guilty plea was not in writing and the government did not consent to it being conditional (C) holding that a complaints reference to a guilty plea does not make the transcript of the plea proffer integral to the complaint (D) holding that the defendants guilty plea was valid where the district court carefully questioned the defendant about whether he understood the consequences of his guilty plea (E) recognizing that a voluntary and understanding guilty plea entered without the benefit of a plea bargain waives all nonjurisdictional defects that occurred before the entry of the plea
[A]:
holding entry of guilty plea waives challenges to the deprivation of constitutional rights that occurred prior to the entry of the guilty plea  emphasis added