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]: to obtain the benefit of the bond, for which it paid a significant premium, only through legal action. Accordingly, Olympic Steamship applies here. Colorado Structures, 125 Wn. App. at 928 (emphasis added) (footnote omitted). We agree. ¶27 Lastly, in McGreevy, where this court awarded reasonable attorney fees in addition to the limits of the insurance policy, we reasoned, “when an insurer unsuccessfully contests coverage, it has placed its interests above the insured. Our decision in Olympic Steamship remedies this inequity by requiring that the insured be made whole.” McGreevy, 128 Wn.2d at 39-40. Likewise, West placed “its interests” above that of Structures. Id. Structures should be awarded attorney fees under Olympic Steamship, so as to be made “whole.” Dayton, 124 Wn.2d at 280 (<HOLDING>)- Without the application of Olympic Steamship 
 Holding statements: (A) holding the contract was not authorized by law (B) recognizing that under georgia law attorneys fees are allowed where authorized by statute or contract (C) holding because an award of attorney fees is discretionary court may consider attorney fees in relation to the underlying equities in the case (D) holding that an award of attorney fees was authorized by ocga  13111 a 3 when the requirements of that statute were satisfied (E) holding that a court has power to award attorney fees when authorized by contract statute or recognized ground of equity
[EX A]: holding the contract was not authorized by law

[EX Q]: unlawful harm under that public policy may include actions that violate recognized and accepted standards of conduct, such as applicable codes of ethics. The critical question in this case is whether under all of the surrounding circumstances MacDougall’s termination by Weiehert violated that clear mandate of public policy and was in retaliation for either his vote on the municipal parking ban ordinance or his refusal to change the ordinance. At the outset, we recognize that conduct that is directed against constitutionally-protected activity may violate a clear mandate of public policy, even though it may not offend any other statutory or legal standard. Supra at 390, 393, 677 A.2d at 167, 168. Compare Shovelin v. Central New Mexico Elec. Coop., Inc., 115 N.M. 293, 850 P.2d 996 (1993) (<HOLDING>) with Novosel v. Nationwide Ins. Co., 721 F.2d 
 Holding statements: (A) holding that employees retaliatory discharge based on employees election to public office did not violate public policy (B) recognizing public policy limits on employer discretion in discharging employees (C) holding public employees conduct and expression in internal investigation of employees at county prosecutors office to expose potential wrongdoing constituted matter of public concern (D) recognizing retaliatory discharge claim where employer prevented employees exercise of workers compensation rights because of employees intention to file claim (E) holding that the discharge of an employee hospitalized for illness did not violate public policy
[EX A]: recognizing public policy limits on employer discretion in discharging employees

[EX Q]: “improper definition of reasonable doubt.” (Claim I.C.4, paragraph 51, of Boyd’s petition.) 23. Boyd alleged that his trial counsel rendered ineffective assistance by failing to object, during the penalty phase of the trial, to the prosecutor’s “expressions of his personal opinion of [Boyd’s] sentence.” (Claim I.D.2, paragraph 62, of Boyd’s petition.) 24. Boyd alleged that his trial counsel rendered ineffective assistance by failing to object, during the penalty phase of the trial, to the prosecutor’s comments “deni-grat[ing] ... the jury’s role in the sentencing process.” (Claim I.D.2, paragraphs 63-64, of Boyd’s petition.) Claims presented in a Rule 32 petition but not pursued on appeal are deemed to be abandoned. See Brownlee v. State, 666 So.2d 91, 93 (Ala.Crim.App.1995)(<HOLDING>). See also, e.g., Charest v. State, 854 So.2d 
 Holding statements: (A) holding that issues not specifically raised and argued in a partys opening brief are waived (B) holding that issues not argued in initial brief are deemed waived (C) holding that we will not review issues not listed and argued in brief (D) holding an appellant may not use the reply brief to argue issues not argued in the initial brief (E) holding issues argued orally but not addressed in brief were waived
[EX A]:
holding that issues not specifically raised and argued in a partys opening brief are waived