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]: Brown’s argument that she was speaking as a citizen is supported by the fact that ordinary citizens may similarly report public misconduct to the Auditors. See Conn. Gen. Stat. § 4-61dd (conferring right to file reports with Auditors on “any person”). The existence of a civilian analogue to Brown’s conduct strengthens her allegations that her speech was as a citizen and thus protected by the First Amendment. See Matthews I, 779 F.3d at 176. The instant case is not similar to other cases of its type that were dismissed at the motion to dismiss stage. In many of those cases, the plaintiff-employee had made an admission that the alleged speech was made, at least in part, pursuant to his or her official duties. See Matthews v. Lynch, 483 Fed.Appx. 624, 626 (2d Cir. 2012) (Matthews III) (<HOLDING>); Anemone, 629 F.3d at 116. Here, there is no 
 Holding statements: (A) holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel (B) holding that a plaintiff did not complain to the eeoc pursuant to official duties but rather as a citizen (C) holding that pursuant to garcetti plaintiffs speech made in the course of his official duties was unprotected as a matter of law (D) holding that speech was pursuant to official duties because plaintiff conceded at oral argument that as an internal affairs officer he had a broad responsibility to investigate and report police misconduct (E) holding police officer is a public official
[EX A]: holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel

[EX Q]: with the general contractor to provide materials and labor. Decina, 258 Mich App at 422. 25 Id. 26 Id. at 423. Although the subcontractors did not contract with the homeowners directly, they were nevertheless at least initially entitled to a construction lien under the CLA. See MCL 570.1107(1) (“Each.. . subcontractor . .. who provides an improvement to real property has a construction lien upon the interest of the owner or lessee who contracted for the improvement to real property .. ..”). 27 H A Smith Lumber & Hardware Co v Decina (On Remand), 265 Mich App 380, 382; 695 NW2d 347 (2005), rev’d 480 Mich 987 (2007). 28 Id. 29 Id. at 384-385. 30 Decina, 480 Mich at 988. 31 id. 32 Decina, 258 Mich App at 424, 431. 33 See MCL 570.1107(1) and (6); see also Vugterveen, 454 Mich at 129 (<HOLDING>). 34 Decina, 480 Mich at 988. 36 MCL 
 Holding statements: (A) recognizing that mcl 57011076 provides a real property owner with a defense to a claim of lien if the owner can show that the sum of payments made pursuant to the specific contract plus the claim of lien exceed the price of the contract (B) holding that the lien bond releases the property from the lien but the lien is then secured by the bond (C) holding that under nebraskas physicians lien statute a physicians lien could not exceed the amount the health care provider agreed to accept for the services rendered to a patient even if the usual and customary charge for such services is greater than that sum because the statute extends such lien only to the amount due or debt of the patient to the hospital (D) holding that the current property owner may not assert a public nuisance claim against the former owner (E) holding a lien is a claim against property  here a surety bond and breach of contract is a claim against a person thus the lien proceeding did not dispose of the breach of contract action
[EX A]: holding that the lien bond releases the property from the lien but the lien is then secured by the bond

[EX Q]: on one.” Strickland, 466 U.S. at 697, 104 S.Ct. at 2069. Capshaw cannot establish that his attorney’s performance was deficient for failing to object to the admission of cell phone records. His trial counsel would not have prevailed on such an objection under the governing law, and thus counsel’s performance was not deficient for failing to object. It is undisputed that the government obtained a court order, under 18 U.S.C. § 2703, requiring Sprint Nextel to produce the cell phone records of Capshaw and three other people to show calls between them during the period of the murder-for-hire plot. Obtaining those telephone rec ords through a § 2703 court order did not violate the Fourth Amendment. See Smith v. Mainland, 442 U.S. 735, 743-44, 99 S.Ct. 2577, 2582, 61 L.Ed.2d 220 (1979) (<HOLDING>). Capshaw had no reasonable expectation of 
 Holding statements: (A) holding anticipatory warrant for search of defendants home was invalid because facts made known to magistrate did not establish at time warrant was issued the required nexus between the contraband to be seized which was mailed to defendants post office box and defendants home (B) holding that search warrant was constitutionally defective because it did not require notice (C) holding that an arrest warrant  without a search warrant  does not permit law enforcement authorities to enter a third partys home to legally search for the subject of the arrest warrant (D) holding that telephone company records of calls made from a defendants home did not require the government to seek a search warrant (E) holding that consent searches do not require probable cause to justify the search of a home
[EX A]:
holding anticipatory warrant for search of defendants home was invalid because facts made known to magistrate did not establish at time warrant was issued the required nexus between the contraband to be seized which was mailed to defendants post office box and defendants home