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.

924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA's one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, U.S. -, 121 S.Ct. 78, 148
Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
holding that issues not raised before the district court cannot be raised for the first time before this court

strengthen, not displace, any existing remedies employees may. have at law." Id. It is clear from these excerpts that the STAA was not enacted to completely preempt state law remedies for retaliation against an employee who refuses to violate safety provisions. See Todd v. Frank's Tong Service, Inc., 784 P.2d 47, 49-50 (Okla.1989) (noting that Congressional intent surrounding enactment of the STAA demonstrates that state law claims are not preempted); see also Parten v. Consolidated Freightways Corp., 923 F.2d 580, 583 (8th Cir.1991) (conclude ing that the Minnesota public policy statute was not an obstacle to the STAA and that Congress did not intend to occupy the entire field of interstate motor carriers); Whitworth v. TNT Bestway Transp., Inc., 914 F.Supp. 1434, 1436 (E.D.Tex.1996) (<HOLDING>); Dobberowsky v. Cryogenic Transp., Inc., 989
Holding statements: (A) holding texas exemption law was not preempted by erisa due to savings clause (B) holding that texas whistleblowers act was not preempted by the staa (C) holding a claim of a violation of the texas dtpa is preempted by the carmack amendment (D) holding that the age discrimination in employment act was not preempted by the nlra (E) holding that where the entity was incorporated in texas and the shareholders reside in texas and the bankruptcy case is pending in texas texas law not arizona law should be applied
holding texas exemption law was not preempted by erisa due to savings clause

(statute of frauds). Carpenter and Carpco further contend the trial court erred in concluding that the contract was partially performed and that promissory estoppel bars the application of the statute of frauds. The trial court found that the alleged contract provided that Phelps and Helms would initially share in a pro rata ownership of 100% of the M.T. Cole "A" lease until net revenues from the wells equaled the principal and interest due the investors, after which Phelps and Helms would share in a pro rata ownership of 50%. On appeal, the parties do not dispute that an agreement assigning such real property interests must contain a description of the property in order to satisfy the statute of frauds. See Westland Oil Dev. Corp. v. Gulf Oil Corp., 637 S.W.2d 903, 908 (Tex.1982) (<HOLDING>); Morrow v. Shotwell, 477 S.W.2d 538, 539
Holding statements: (A) recognizing that a metes and bounds partition when land contains oil and gas results in a serious loss to a coowner who receives a lot without oil or gas under the surface with the loss due solely to the division of the land (B) holding provision in oil and gas lease authorizing lessor to use gas for agricultural purposes contained no geographical limitations (C) recognizing oil gas and coal are minerals and holding if oil gas and minerals are reserved from the grant of the surface of several tracts of unseated land they can be taxed as an estate in land (D) holding that allegations that states lease and actions that resulted in taking of oil and gas were sufficient to state claim for inverse condemnation (E) holding assignment of oil and gas lease is subject to business and commerce code section 2601
recognizing that a metes and bounds partition when land contains oil and gas results in a serious loss to a coowner who receives a lot without oil or gas under the surface with the loss due solely to the division of the land