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.

[EX Q]: in cases decided under the Bankruptcy Code. See, e.g., In re Meyers, 616 F.3d 626, 628 (7th Cir. 2010) (characterizing the Segal standard as a "background rule under the old Bankruptcy Act, to which courts still refer in the era of the Bankruptcy Code”); Andrews, 80 F.3d at 910-11 (applying the Segal standard to determine whether post-petition payments under a pre-petition non-compete agreement were property of the debtor’s estate); Ryerson, 739 F.2d at 1423 (concluding the Bankruptcy Code "follows Segal insofar as it includes after-acquired property 'sufficiently rooted in the prebankruptcy past’ but eliminates the requirement that it not be entangled with the debtor’s ability to make a fresh start”). But see Burgess v. Sikes (In re Burgess), 438 F.3d 493, 498 (5th Cir.2006) (en banc) (<HOLDING>). 13 . Although the parties frame the issue as 
 Holding statements: (A) holding that the eleventh amendment does not bar a bankruptcy court from issuing a money judgment against a state under the bankruptcy code (B) holding that bankruptcy court is without jurisdiction to control disposition of chapter 13 debtors property that is not property of the bankruptcy estate unless the property is related to the bankruptcy proceedings of the code (C) holding that the question of whether an interest is a claim for bankruptcy purposes is to be resolved by reference to the text history and purpose of the bankruptcy code (D) holding although congress has specifically approved of segals result segals sufficiently rooted test did not survive the enactment of the bankruptcy code footnote omitted (E) holding that the bankruptcy code endows the bankruptcy trustee with the exclusive right to sue on behalf of the estate
[EX A]: holding that the eleventh amendment does not bar a bankruptcy court from issuing a money judgment against a state under the bankruptcy code

[EX Q]: court’s conclusion that the Jarvisons had a traditional ceremonial marriage under the Navajo Code. Moreover, because the Jarvi-sons had not completed the procedure under Navajo law to validate a traditional or common law marriage, the government argues that their marriage was invalid. In evaluating the government’s contentions, we observe that the district court could have produced a more robust order detailing its findings of fact and evidentia-ry basis similar to the detailed findings of fact and conclusions of law in Beller v. United States, 221 F.R.D. 679 (D.N.M.2003). Nonetheless, on our review of the record, we conclude that the evidence in the record is sufficient to establish a valid marriage between the Jarvisons. See United States v. Taylor, 97 F.3d 1360, 1364 (10th Cir.1996) (<HOLDING>). In this case, Esther testified to having 
 Holding statements: (A) holding that despite a trial courts failure to make specific factual findings an appellate court is free to affirm on any grounds for which there is sufficient record to permit conclusions of law (B) holding an appellate court is not limited to the grounds offered by the trial court in support of its decision and may affirm on any ground on which additional factual findings are not required (C) holding that an appellate court can affirm a district courts order on any basis for which there is a record sufficient to permit conclusions of law including grounds upon which the district court did not rely (D) holding this court may affirm on any grounds supported by the record even if different from the district courts grounds (E) holding that it is not an appellate courts function to make findings of fact
[EX A]: holding an appellate court is not limited to the grounds offered by the trial court in support of its decision and may affirm on any ground on which additional factual findings are not required

[EX Q]: (D.D.C.1987), aff'd, 848 F.2d 1283 (D.C.Cir.1988) (explaining that the pleader must allege with particularity the alleged fraud to survive a Rule 9(b) motion). Finally, “[c]onclusory allegations that a defendant’s actions were fraudulent and deceptive are not sufficient to satisfy 9(b).” Shekoyan v. Sibley Int’l Corp., 217 F.Supp.2d 59, 73 (D.D.C.2002); see also In re Rockefeller Ctr. Props. Inc. Sec. Litig., 311 F.3d 198, 216 (3d Cir.2002) (noting that courts are not required to credit a complaint’s bald assertions, legal conclusions or “legal conclusions draped in the guise of factual allegations”) Where a pleading does not satisfy the heightened requirements of Rule 9(b), the court should freely grant leave to amend. See Firestone v. Firestone, 76 F.3d 1205, 1209 (D.C.Cir.1996) (<HOLDING>). Accordingly, the court should reserve 
 Holding statements: (A) holding that dismissal with leave to amend should be granted even if no request to amend was made (B) holding that a district court should grant leave to amend unless it determines that the pleading could not possibly be cured by the allegation of other facts (C) holding the district court is not required to grant a plaintiff leave to amend his complaint sua sponte when the plaintiff who is represented by counsel never filed a motion to amend nor requested leave to amend before the district court (D) recognizing that courts almost always grant leave to amend to cure deficiencies in pleading fraud (E) recognizing that courts freely grant pro se litigants leave to amend
[EX A]:
holding that dismissal with leave to amend should be granted even if no request to amend was made