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.

clause could be vitiated based on evidence of fraud "relating to the merger clause or fraud that invalidates the entire contract including the merger clause." 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs' allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 ("Fraud ... makes a contract voidable at the instance of the innocent party.") (quoting 3 Corbin, Contracts, 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs' argument conflates their tort
Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable
holding that a contract made in violation of section 432070 is void rather than voidable

motion at which Pritchett would be represented by counsel or at which the court would determine that Pritchett knowingly, intelligently, and voluntarily waived his right to counsel. Ex parte Pritchett, 117 So.3d at 362. In the instant case, the circuit court immediately appointed new counsel to represent Trimble after Trimble gave his oral notice of appeal. Despite having newly appointed counsel who could file a motion for a new trial attacking his trial counsel's alleged deficiencies, Trimble elected to file a pro se motion for a new trial. Therefore, unlike the defendant in Pritchett, Trimble had the benefit of newly appointed appellate counsel who represented him and who could file a motion for a new trial on his behalf. See King v. State, 613 So.2d 888 (Ala.Crim.App.1993)
Holding statements: (A) holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage (B) holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver (C) holding postindictment lineup is critical stage of trial at which defendant is entitled to presence of counsel (D) holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage (E) holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel
holding that a valid waiver of counsel at an early stage of the proceeding does not continue in effect through a subsequent stage

which makes the actor negligent, such an act whether innocent, negligent, intentionally tor-tious, or criminal does not prevent the actor from being liable for harm caused thereby."). 14 . Although we have cited 302B several times in dicta, this court has never invoked that section as a source of liability. See Bryson v. Banner Health Sys., 89 P.3d 800, 805 n. 11 (Alaska 2004) (quoting almost identical language in Prosser and Keeton on Torts for the proposition that a special relationship may yield a duty to protect another from a third party); Joseph v. State, 26 P.3d 459, 471 n. 67 (Alaska 2001) (citing 302B for the proposition that "a reasonably foreseeable occurrence cannot be an intervening/superseding cause if the actor has a duty to prevent that occurrence"); Wil 011) (<HOLDING>); Kim v. Budget Rent A Car Sys., Inc., 143
Holding statements: (A) holding that a prior conviction for abusive sexual contact under 18 usc 2244a3 was a per se crime of violence within the meaning of the application notes and declining to consider application of the residual clause (B) holding that defendants constitutionally protected privacy interest began at the door to his room not at the door to the rooming house (C) holding that violence was not the foreseeable result of opening the door to an abusive and upset exhusband while a new boyfriend was over (D) holding that opening the door in response to a police demand and then failing to object when officers entered was not voluntary consent (E) holding that arrest by the back door of defendants house was unlawful
holding that a prior conviction for abusive sexual contact under 18 usc 2244a3 was a per se crime of violence within the meaning of the application notes and declining to consider application of the residual clause