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]: This Court has reviewed these decisions and is in agreement with their reasoning and conclusions that the public policy exception does not give rise to a protected property interest in continued employment in this case. Likewise, the implied covenant is not the source of a protected property interest. The implied covenant of good faith and fair dealing applies to at-will employment and affords an employee the right to be dealt with fairly and in good faith. See Cantwell v. City of Boise, 146 Idaho 127, 191 P.3d 205, 213-14 (2008). Breach of the covenant may give rise to an action for wrongful termination but it does not convert at-will employment to term employment nor form the basis for a protected property interest. See Hollister v. Forsythe, 22 F.3d 950, 952-52 (9th Cir.1994) (<HOLDING>); Willnerd v. Sybase, Inc., No.
Holding statements: (A) recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate (B) recognizing cause of action for implied covenant of good faith and fair dealing in atwill employment contract (C) holding an implied covenant of good faith and fair dealing was insufficient to create a property interest in continued employment under montanas statutory scheme for at will employment (D) holding that the implied covenant of good faith and fair dealing is limited to performance under a contract (E) recognizing that evidence of breach of implied covenant of good faith and fair dealing may support punitive damages
[A]: recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate

[Q]: 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
[A]: holding that issues not raised before the district court cannot be raised for the first time before this court

[Q]: were all based on these claims and are now mooted. 53 . Valdez Fisheries Dev. Ass'n, Inc. v. Alyeska Pipeline Serv. Co., 45 P.3d 657, 671 (Alaska 2002). 54 . Thompson's Estate v. Mercedes-Benz, Inc., 514 P.2d 1269, 1271 (Alaska 1973). 55 . 3 Jamrs Wa Moore, Feperat Practice 15.14[1] (3d ed.2003). 56 . 371 U.S. 178, 182, 83 S.Ct. 227, 9 LEd.2d 222 (1962). 57 . Betz v. Chena Hot Springs Group, 742 P.2d 1346, 1348 (Alaska 1987) (citing Foman, 371 U.S. at 182, 83 S.Ct. 227). 58 . Thompson's Estate, 514 P.2d at 1271. 59 . Betz, 742 P.2d at 1348. 60 . Kittredge Sports Co. v. Superior Court, 213 Cal.App.3d 1045, 261 Cal.Rptr. 857, 859-60 (1989) (citing Higgins v. Del Faro, 123 Cal.App.3d 558, 176 Cal.Rptr. 704 (1981)); see also Smith v. Costa Lines, Inc., 97 F.R.D. 451, 453 (N.D.Cal.1983) (<HOLDING>); Karn v. Coldwell Banker Residential Real
Holding statements: (A) holding that it was not an abuse of discretion for the court to deny an award of attorneys fees to the wife (B) holding it was not an abuse of discretion to deny funds (C) holding district court abused discretion in denying leave to amend complaint to add claim when party opposing motion made no showing of prejudice from delay (D) holding not an abuse of discretion to deny funds (E) holding that it may be held an abuse of discretion for the court to deny leave unless there is a demonstrable showing of prejudice to an opposing party
[A]:
holding that it was not an abuse of discretion for the court to deny an award of attorneys fees to the wife