Q: 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.
three additional bases for equitably tolling 2244(d)'s one-year limitation period: (1) "his lack of access to legal resources," (2) "his lack of legal knowledge," and (3) his "medical disability" (depression). R. at 64. In his filings with this court, however, Mr. Sandoval does not renew these claims. Instead, he simply states that he "explained the circumstances beyond [his] control" during "habeas review." Aplt. Opening Br. for Appl. for COA at 2. Insofar as this could be read as an attempt to incorporate the three arguments by reference, this practice is generally disfavored in this circuit. See 10th Cir. R. 28.4 ("Incorporating by reference portions of lower court or agency briefs or pleadings is disapproved."); see also Wardell v. Duncan, 470 F.3d 954, 963-64 (10th Cir.2006) (<HOLDING>); Gaines-Tabb v. ICI Explosives, USA, Inc., 160
Holding statements: (A) holding that a defendant proceeding pro se is bound by same rules as party represented by counsel and a court cannot allow pro se litigant lower standard of performance (B) holding that courts must construe pro se filings liberally (C) holding that the appellant could not incorporate district court filings into his appellate brief by reference and that his pro se status did not except him from such established rules (D) holding that nonlawyer proceeding pro se could not represent his children (E) holding that although pro se briefs are liberally construed even pro se litigants must brief arguments in order to preserve them
A:
holding that a defendant proceeding pro se is bound by same rules as party represented by counsel and a court cannot allow pro se litigant lower standard of performance