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: but rather affords a bright-line, legal presumption of coercion, requiring suppression of all unwarned statements." Oregon v. Elstad, 470 U.S. 298, 306 n. 1, 105 S.Ct. 1285, 1292 n. 1, 84 L.Ed.2d 222, 23 2 L.Ed.2d 975 (1958) (same). Essentially, the Court determined that the prejudicial quality of testimony regarding an actually coerced confession is, like all other improperly introduced testimony at trial, capable of review. At this point in time, the Fulminante decision stands as the sole, albeit the dispositive, case on this point. In contrast, cases applying the harmless error analysis to the introduction of presumptively coerced statements are legion. See e.g. Pennsylvania v. Muniz, 496 U.S. 582, 605 & n. 22, 110 S.Ct. 2638, 2652 & n. 22, 110 L.Ed.2d 528, 555 & n. 22 (1990) (<HOLDING>); Berkemer v. McCarty, 468 U.S. 420, 443, 104
Holding statements: (A) holding that waiver of miranda rights was valid where finding that the defendant initiated the conversation was implicit in the district judges denial of the suppression motion (B) holding that in order to conclude that federal constitutional error is harmless court must find that error harmless beyond a reasonable doubt (C) holding that booker constitutional error was harmless beyond a reasonable doubt because on remand the district court would have given defendant the same sentence (D) holding that although defendant was a deputy sheriff miranda warnings were required irrespective of defendants knowledge of his fifth amendment rights (E) holding that although miranda required the suppression of testimonial statements made before defendant was advised of his constitutional rights the state court is free of course to consider this harmless error question upon remand

A: holding that waiver of miranda rights was valid where finding that the defendant initiated the conversation was implicit in the district judges denial of the suppression motion
****
Q: was merely a voidable act. They rely on Sikes v. Global Marine, Inc., 881 F.2d 176 (5th Cir.1989), rehearing denied by 888 F.2d 1388 (5th Cir.1989), in which the Fifth Circuit found that the filing of a complaint in violation of the stay was voidable but not void. Id. at 178-79. The court reasoned that provisions of the Bankruptcy Code such as section 362(d), by giving courts the power to grant retroactive relief from a stay, indicated Congressional intent that acts in violation of a stay be simply voidable. Id. Spring Meadows, however, urges us to adopt the rule of the Ninth Circuit that any act committed in violation of an automatic stay is void. Hillis Motors, Inc. v. Hawaii Auto. Dealers Ass'n, 997 F.2d 581, 586 (9th Cir.1993); In re Schwartz, 954 F.2d 569, 571-72 (9th Cir.1992) (<HOLDING>). The circuit court found such acts void even
Holding statements: (A) recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect (B) holding that violations of the automatic stay are void and rejecting the reasoning of sikes (C) holding judgment in violation of automatic stay void (D) holding that the automatic stay did not bar the filing of a proof of claim where the debtor actively litigated a separate action during the pending bankruptcy proceeding because to permit the automatic stay provision to be used as a trump card played after an unfavorable result was reached would be inconsistent with the underlying purpose of the automatic stay (E) holding that an action taken in violation of the automatic stay is void ab initio

A: recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect
****
Q: at 4. This finding of bad faith is amply supported by the record: Sauers admitted that he could not present facts to challenge the Commissioner's determination of tax deficiency, he refused to engage in a stipulation of facts, and his legal arguments have been repeatedly rejected by the courts. See, e.g., Welch v. Helvering, 290 U.S. 111, 54 S.Ct. 8, 78 L.Ed. 212 (1933) (establishing that burden of proof in Tax Court is on the taxpayer); Nash Miami Motors, Inc. v. Commissioner, 358 F.2d 636 (5th Cir.), cert. denied, 385 U.S. 918, 87 S.Ct. 227, 17 L.Ed.2d 142 (1966) (relying on Ex parte Bakelite Corp., 279 U.S. 438, 49 S.Ct. 411, 73 L.Ed. 789 (1929) for the conclusion that the statute establishing the Tax Court does not unconstitutionally violate separation of powers); Larsen at 941-942 (<HOLDING>); Wright v. Commissioner, 752 F.2d 1059, 1062
Holding statements: (A) holding no first amendment right to file frivolous grievances (B) holding that the court of claims did not have jurisdiction over plaintiffs first amendment claim of improper removal (C) holding that article iii courts have an independent obligation to determine whether subject matter jurisdiction exists (D) holding the following claims to be frivolous 6673 infringes upon first amendment right to petition tax court cannot have jurisdiction because it is not an article iii court (E) holding that the bankruptcy courts jurisdiction to adjudicate common law claims violated article iii without deciding the claims

A:
holding no first amendment right to file frivolous grievances
****