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.

Example Input: plain error review because he did not object to the admissibility of the reports or to the testimony by Detective Duft about the report. See State v. Parker, 350 N.C. 411, 427, 516 S.E.2d 106, 118 (1999) (plain error is error "so fundamental as to amount to a miscarriage of justice or which probably resulted in the jury reaching a different verdict than it otherwise would have reached."). Indeed, Defendant never disputed that the material was cocaine. He chose not to defend on that basis, but rather focused on portraying himself as a homeless person making a delivery in exchange for beer and cigarettes. Since the identity of the substance was not challenged, the admission of the laboratory reports was harmless error. See State v. Edwards, - N.C. App. -,-, 621 S.E.2d 333, 337 (2005), (<HOLDING>); State v. Thompson, 110 N.C. App. 217, 225,
Holding statements: (A) holding that trial delay for dna testing was attributable to the state but was mere negligence (B) holding that failure to require production of dna testing protocols was harmless beyond a reasonable doubt when the defendant did not dispute that he committed the crimes at issue but rather argued that he was mentally impaired (C) holding that the sixth amendment confrontation clause violation in that case was harmless beyond a reasonable doubt and therefore did not require the conviction to be overturned (D) holding that harmless beyond a reasonable doubt analysis not applicable in habeas cases (E) holding the state failed to meet its burden of showing the erroneous jury instruction was harmless beyond a reasonable doubt where it did not address the issue on appeal
Example Output: holding that trial delay for dna testing was attributable to the state but was mere negligence

Example Input: (citations omitted). Kaul believes that because the Court did not include seizing cigarettes fi*om Indians inside a reservation on this list, Stephan lacked jurisdiction to execute the search warrant at Kaul's store. However, we do not read Oklahoma Tax Commission and Colville as necessarily prohibiting state officers from conducting search and seizure operations within a reservation's borders under the authority of a federal grant of criminal jurisdiction to the state. Instead, these opinions merely offer several options that state officials may employ to enforce regulatory cigarette tax statutes. Here, Kaul waived the argument that the Kansas statute was regulatory in nature because she did not raise that issue below. Thus, for purposes of this appea 3, 2061, 109 L.Ed.2d 693 (1990) (<HOLDING>). Furthermore, the Supreme Court has long held
Holding statements: (A) holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction (B) recognizing the inherent power of indian tribes to exercise criminal jurisdiction over all indians (C) holding that indian tribes lack tribal jurisdiction over crimes committed by nonmember indians within the tribes reservation (D) holding that indian tribes could only exercise criminal jurisdiction over tribal members and not other indians (E) holding that an indian tribes exercise of criminal jurisdiction over nonindians is inconsistent with the domesticdependent status of the tribes and that tribes may not assume such jurisdiction without congressional authorization
Example Output: holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction

Example Input: that a stipulation "waives the requirement that the government produce evidence (other than the stipulation itself) to establish the facts stipulated to beyond a reasonable doubt." Id. at 678 (emphasis added) (citing United States v. Clark, 993 F.2d 402, 406 (4th Cir.1993)). Arguably, the italicized phrase contemplates a formal reading to the jury of all necessary stipulations. But that issue was not before the court. The stipulation was read aloud in Muse (and in the case it cited for support), see id. at 678; the actual issue was the propriety of a jury instruction. See id. at 677. Therefore, while' the Muse court accurately described normal trial practice to include the reading of stipulations, it had no occasion to consider the situation before us today. See Hardin, 139 F.3d at 817 (<HOLDING>); see also United States v. Jackson, 124 F.3d
Holding statements: (A) holding that references to reading stipulations in muse are dicta (B) holding that everything after denial of jurisdiction is dicta pure and simple (C) recognizing such limitations in dicta (D) recognizing that alternative holdings are not dicta (E) recognizing that a reading of the oregon criminal statute indicates that the acts prohibited are those which are performed upon the mother rather than any action taken by her
Example Output:
holding that everything after denial of jurisdiction is dicta pure and simple