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.

Plaintiff asserts that his right to the foreshore did not derive from a grant from the State, but instead from a colonial grant from Thomas Dongan, the Governor of Staten Island. Even if the court were to consider Plaintiffs post-trial submissions, including the Dongan grant and the Caleb Ward deeds, the court would find that Plaintiff did not own the foreshore. The Dongan Grant transferred to Christopher Billopp approximately 1600 acres of property on Staten Island and designated that the foreshore was included in the boundary of the property. Pl.Ex. Bl. New York courts have found, under the public trust doctrine, that large grants of land to private individuals are ultra vires and void. See Marba Sea Bay Corp. v. Clinton St. Realty Corp., 272 N.Y. 292, 296, 5 N.E.2d 824 (1936) (<HOLDING>); Coxe v. State, 144 N.Y. 396, 406, 39 N.E. 400
Holding statements: (A) holding where plan language can be interpreted both to grant discretion and not to grant discretion plan does not unambiguously grant discretion (B) holding that a state has subject matter jurisdiction to grant a divorce if one of the spouses is domiciled in the state (C) holding that the trial court may not grant summary judgment on a ground not raised in the motion (D) holding that a report relied upon by agency in determining whether or not to award a grant had not been adopted as there is no indication in the record that in funding the grant the agency expressly adopted the reasoning of the report (E) holding in reference to an eleven mile grant of the foreshore that neither the king nor the state could grant away for private purposes so much of the publics rights in the lands under water
holding where plan language can be interpreted both to grant discretion and not to grant discretion plan does not unambiguously grant discretion