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: with the general contractor to provide materials and labor. Decina, 258 Mich App at 422. 25 Id. 26 Id. at 423. Although the subcontractors did not contract with the homeowners directly, they were nevertheless at least initially entitled to a construction lien under the CLA. See MCL 570.1107(1) ("Each.. . subcontractor . .. who provides an improvement to real property has a construction lien upon the interest of the owner or lessee who contracted for the improvement to real property .. .."). 27 H A Smith Lumber & Hardware Co v Decina (On Remand), 265 Mich App 380, 382; 695 NW2d 347 (2005), rev'd 480 Mich 987 (2007). 28 Id. 29 Id. at 384-385. 30 Decina, 480 Mich at 988. 31 id. 32 Decina, 258 Mich App at 424, 431. 33 See MCL 570.1107(1) and (6); see also Vugterveen, 454 Mich at 129 (<HOLDING>). 34 Decina, 480 Mich at 988. 36 MCL
Holding statements: (A) recognizing that mcl 57011076 provides a real property owner with a defense to a claim of lien if the owner can show that the sum of payments made pursuant to the specific contract plus the claim of lien exceed the price of the contract (B) holding that the lien bond releases the property from the lien but the lien is then secured by the bond (C) holding that under nebraskas physicians lien statute a physicians lien could not exceed the amount the health care provider agreed to accept for the services rendered to a patient even if the usual and customary charge for such services is greater than that sum because the statute extends such lien only to the amount due or debt of the patient to the hospital (D) holding that the current property owner may not assert a public nuisance claim against the former owner (E) holding a lien is a claim against property here a surety bond and breach of contract is a claim against a person thus the lien proceeding did not dispose of the breach of contract action

A: holding that the lien bond releases the property from the lien but the lien is then secured by the bond
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Q: and seeking to dismiss the four new claims asserted against them in the amended complaint. Also on January 8, 2010, Wells Fargo filed a supplemental motion to dismiss [26], addressing the new claims against it and renewing its request that all counts be dismissed. II. Discussion The Court must determine whether: (1) Giscombe eliminated the deficiencies of his previous shotgun pleading, and (2) if so, whether the complaint should be dismissed for the other reasons asserted by ABN, Citimortgage, and Wells Fargo in their motions to dismiss. A. Legal Standard The sufficiency of Giscombe's amended complaint depends on whether it is a shotgun pleading; if so, it will fall short of the pleading requirements of Fed.R.Civ.P. 8. Magluta v. Samples, 256 F.3d 1282, 1284-85 (11th Cir.2001) (<HOLDING>). The defining characteristic of a shotgun
Holding statements: (A) recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure (B) holding that under leatherman a federal court may not apply a pleading requirement more stringent than that provided for in the federal rules of civil procedure even in 1983 litigation (C) holding that discovery under the federal rules of civil procedure is broad in scope and freely permitted (D) holding that the fact that federal rule of civil procedure 9b requires a heightened pleading standard for some claims but not for a section 1983 claim against a municipality means that the rules do not require a heightened pleading standard for such a claim (E) holding that a shotgun pleading is in no sense the short and plain statement of a claim required by rule 8 of the federal rules of civil procedure

A: recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure
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Q: 1179 n. 7 (8th Cir.1990) ("While [the McBroom factors cited in Baer] may have been relevant and sufficient in Baer to require the state to permit party designation, the same factors might not be relevant in a different context.... We too [having just cited this Court's subsequent decision in Rainbow Coalition ] reject these factors as the exclusive or even necessarily the most reliable, indicators of the state registration procedure's constitutionality."), with Atherton v. Ward, 22 F.Supp.2d 1265, 1267-68 (W.D.Okla.1998) (noting that it was "bound by ... Baer" and concluding that there was "no difference in a constitutional sense between Oldahoma law and the Colorado law at issue in Baer"). See also Green Party of N.Y. v. N.Y. State Bd. of Elections, 389 F.3d 411, 422 (2d Cir.2004) (<HOLDING>). 6 . Our decision in Rainbow Coalition of
Holding statements: (A) recognizing the states interest in preventing deception of consumers (B) holding that the governor did not have to obtain the consent of the senate for the appointment of a candidate when the first candidate had been rejected by the senate the senate was not in session at the time that the second candidate was appointed and because the legislature which created and therefore controlled the office did not require by statute that the governor seek the senates approval in those circumstances (C) recognizing that baer did not state a universal brightline rule for drawing the line with frivolous party registration but like baer holding that the ability to meet the requirements for placing a candidate on the statewide ballot is enough of an indication of support to overcome the states interest in preventing voter confusion (D) holding that the government interest in preventing crime is compelling (E) holding that an oklahoma law placing democratic party candidates in the highest ballot positions violated the equal protection clause

A:
recognizing the states interest in preventing deception of consumers
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