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: quantity function as elements by increasing the maximum penalty a defendant may receive, are they elements of an aggravated offense or are they sentencing factors with heightened due process requirements? See id. at 573, 575 (Hug, J., concurring) (disagreeing with the majority's apparent conclusion that the penalty provisions of 841(b) are not elements of the offense). The district court correctly interpreted Buckland as holding that drug type and quantity are not elements of the offense, but rather are material facts that must be submitted to the jury and proved beyond a reasonable doubt. The Buckland opinion emphasized that the relevant inquiry is not whether a penalty provision is an element, but rather whether it exposes the defendant to a longer sentence than woul (9th Cir.2002) (<HOLDING>); United States v. Minore, 292 F.3d 1109,
Holding statements: (A) recognizing that sentencing judges have the discretion to reject any sentencing guideline but no judge is required to do so (B) holding jury is entitled to accept the states version of the facts and reject appellants version or reject any of the witnesses testimony (C) holding that biased on buckland we must reject valensias contention that the sentencing provisions of 841 create separate crimes (D) holding that under the crimes code conspiracy and the completed substantive offense are separate crimes (E) holding the crimes merge where the jury was not asked to determine whether two assaults occurredeventhough the evidence may have been sufficient to support separate crimes
Example Output: recognizing that sentencing judges have the discretion to reject any sentencing guideline but no judge is required to do so

Example Input: and Waste Control Specialists. LLC v. Sierra Club, appellate cause number. 03-12-00335-CV. 4 . See Sierra Club v. Texas Commission on Environmental Quality, cause number D-l-GN-12-001586. 5 .Despite this, the trial court issued a written order denying the motion twenty days after the deadline for ruling on the motion had passed. The order though included in the record on appeal is of no effect. Jain v. Cambridge Petroleum Grp., Inc., 395 S.W.3d 394, 396 (Tex.App.-Dallas 2013, no pet.) ("The trial court's signing the order denying the motion [to dismiss pursuant to the Act] after it was already denied by operation of law is legally of no effect because the motion to dismiss was already denied."); reran v. Fryer, 586 S.W.2d 699, 700 (Tex.Civ.App.-Cor-pus Christi 1979, writ ref'd) (<HOLDING>). 6 . Appellees also insist that Sierra Club
Holding statements: (A) holding that an order purporting to amend a judgment was void because it was entered after the trial court had lost jurisdiction to rule on the parties postjudgment motions (B) holding court lost jurisdiction to enter its order after thirty days and the motion was denied by operation of law (C) holding trial court did not abuse discretion in denying motion for new trial by operation of law because motion was not properly presented even though a notice of presentment was filed and the docket sheet contained an entry for the motion having been filed (D) holding that a district courts order of dismissal with prejudice was a nullity because the court lacked jurisdiction (E) holding that an order purporting to overrule a motion for new trial that had already been overruled by operation of law was a nullity
Example Output: holding that an order purporting to amend a judgment was void because it was entered after the trial court had lost jurisdiction to rule on the parties postjudgment motions

Example Input: proceeding, an appellant must first obtain a COA. Jackson v. Crosby, 437 F.3d 1290, 1294-95 (11th Cir.2006). The court that issues a COA must "indicate which specific issue or issues," if any, warrant a COA. 28 U.S.C. 2253(c)(3). Appellate review is then limited to the issues specified in the COA. Murray v. United States, 145 F.3d 1249, 1250-51 (11th Cir.1998). Here, however, the dis trict court failed to specify which issues or issues warranted a COA. Because the court failed to specify the issue or issues for which it granted a COA, we may do one of two things: (1) remand to the district court for enumeration of issues; or (2) retain jurisdiction and rule on those issues raised by the prisoner that we deem worthy of a COA. See Putman v. Head, 268 F.3d 1223, 1227-28 (11th Cir.2001) (<HOLDING>); Moore v. Campbell, 344 F.3d 1313, 1315 n. 1
Holding statements: (A) holding that the district courts failure to enumerate specific issues for review in a coa does not deprive us of appellate jurisdiction (B) holding the scope of appellate review of denial of a habeas petition limited to the issues on which coa has been granted (C) holding that on appeal from the denial of a 2255 motion appellate review is limited to the issues specified in the coa (D) holding that appellate review is limited to the issues specified in the coa (E) holding that appellate review in a habeas ease is limited to the issues specified in the coa
Example Output:
holding the scope of appellate review of denial of a habeas petition limited to the issues on which coa has been granted