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]: of the evidence to have determined the outcome." Id.; accord Snow v. State, 697 S.W.2d 663, 666-68 (Tex.App.-Houston [1st Dist.] 1985), pet. dism'd, 794 S.W.2d 371 (Tex.Crim.App.1987). A "single egregious error" may constitute ineffective assistance. Thompson, 9 S.W.3d at 813. Frequently, it has. Texas Cases Reversing Without Evidence of Trial Strategy In at least 22 cases decided after the Court of Criminal Appeals decided Jackson v. State, Texas courts have reversed even though no evidence of trial counsel's reasoning was presented. See Woods v. State, 59 S.W.3d 833, 835-38 (Tex.App.-Texarkana 2001, pet. filed); Mares v. State, 52 S.W.3d 886, 893 (Tex.App.-San Antonio 2001, pet. ref'd); Jaubert v. State, 65 S.W.3d 73 (Tex.App.-Waco 2000, pet. granted) (designated for publication) (<HOLDING>); Robison v. State, 35 S.W.3d 257, 265
Holding statements: (A) recognizing rule (B) recognizing a limited exception to the eightcorners rule for a pure coverage question where the insurer is not questioning the merits of the underlying thirdparty claim and the extrinsic evidence goes strictly to an issue of coverage without contradicting any allegation in the thirdparty claimants pleadings material to the merits of that underlying claim (C) recognizing that sanctions are collateral to the merits of the case and may be considered even after the merits are no longer before the district court (D) holding that procedural bar rule does not apply to ineffectiveness claims (E) recognizing the rule in robinson and reviewing the merits of ineffectiveness claim without evidence of trial counsels strategy
[A]: recognizing rule

[Q]: acted outside their jurisdiction. In sum, none of Pasiewicz's arguments show that Sandahl and Henning violated the Constitution when they arrested him. They and the other officers (Johnson in particular) certainly could have, and we think should have, proceeded with more caution. They get no commendation ribbons for the way they handled this case. Pasiewicz's claim against the forest preserve district (even assuming it's a suable entity) for failure to train or supervise its officers properly regarding the laws of search, seizure, and jurisdiction is a born loser. Because the officers did not violate Pasiewicz's constitutional rights, he did not suffer constitutional injury. Accordingly, under City of Los Angeles v. Heller, 475 U.S. 796, 799, 106 S.Ct. 1571, 89 L.Ed. 1412 (D.D.C.1983) (<HOLDING>), it is worth pointing out that Ross involved
Holding statements: (A) holding that knockandannounce principle is an element of the fourth amendment reasonableness inquiry because we have little doubt that the framers of the fourth amendment thought that the method of an officers entry into a dwelling was among the factors to be considered in assessing the reasonableness of a search and seizure (B) holding that an arrest made by an officer outside his jurisdiction does not violate the fourth amendment (C) holding that whether an officers force was reasonable must be analyzed under the reasonableness standard of the fourth amendment (D) holding that a search incident to a lawful arrest does not violate the fourth amendment (E) holding that the concept of reasonableness in the fourth amendment logically presupposes an exercise of lawful authority by a police officer
[A]: holding that knockandannounce principle is an element of the fourth amendment reasonableness inquiry because we have little doubt that the framers of the fourth amendment thought that the method of an officers entry into a dwelling was among the factors to be considered in assessing the reasonableness of a search and seizure

[Q]: position. In arguing that a claimant's submission is not truly "false" if the government knows it to be untrue, the Defendants are actually arguing that when the government remits payment on a claim knowing that a certification contained therein is false, the government waives its right to pursue a cause of action under the civil FCA. We find this position untenable for a number of reasons. Initially, we note that the falsity of a claim is determined at the time of submission. If a claimant has submitted a claim (i.e., a request or demand for money or property) to the government and the claimant knows that he or she is not actually entitled to the funds or property in question, the claimant has asserted a false claim. Fortuities in th y, 82 F.3d 624, 633 n. 11 (5th Cir.1996) (<HOLDING>). In addition, the Defendants' position is
Holding statements: (A) holding that all claims submitted by defendant were false because they were acquired by kickback (B) holding that the defendant could be prosecuted for making false claims against the government under either the false claims statute 18 usc 287 or the mail and wire fraud statutes 18 usc 1341 1343 (C) holding that the defendant contractor violated 18 usc 286 a companion statute to the criminal fca because his claims were false when submitted even though the false claims were ultimately irrelevant to the total amount paid by the government to the contractor (D) holding that the government could not charge contractor excess cost of relet contract where government caused a delay in contract performance in which contractor was to use his own equipment original contractors costs increased and government refused to allow original contractor to perform at cost but allowed new contractor to use government equipment and paid new contractor a different rate (E) holding that apparel cleaners submission of false statements of their receipts a percentage of which were to be paid to the united states did not constitute false claims within the meaning of the federal false claims act
[A]:
holding that all claims submitted by defendant were false because they were acquired by kickback