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]: act, 1976 PA 267, MCL 15.261 to 15.275. (3) If the board arbitrarily and capriciously violates section 7(9), the board shall he subject to the penalties prescribed in the freedom of information act, 1976 PA 442, MCL 15.231 to 15.246. B If "a statute gives new rights and prescribes new remedies, such remedies must be strictly pursued; and a party seeking a remedy under the act is confined to the remedy conferred thereby and to that only." Monroe Beverage Co, Inc v Stroh Brewery Co, 454 Mich 41, 45; 559 NW2d 297 (1997) (quotation marks and citation omitted). However, "[w]hen a statute provides a remedy for enforcement of a common-law right, the statutory scheme is merely cumulative and not exclusive." Morris Pumps v Centerline Piping, Inc, 273 Mich App 187, 201; 729 NW2d 898 (2006) (<HOLDING>). At common law there has always been a remedy
Holding statements: (A) holding that because the federal arbitration act 9 usc 1 et seq preempts michigans lemon law mcl 2571401 et seq the plaintiffs lemon law claim should have been resolved through binding arbitration (B) holding that the plaintiffs claims for unjust enrichment were not barred by the availability of relief under the public works bonding act mcl 129201 et seq because a plaintiff enjoyed the right at common law to recover in quantum meruit from a defendant who had been unjustly enriched (C) recognizing that action for quantum meruit relief exists to avoid unjust enrichment (D) holding preemption is appropriate where unjust enrichment claim does not allege that the defendants were enriched by anything other than copyright infringement (E) holding that erisa does not permit a plaintiff to assert an independent federal common law cause of action such as unjust enrichment to enforce the terms of an erisa plan thus to the extent plaintiffs third cause of action for unjust enrichment is brought pursuant to a federal common law right it must be dismissed
[A]: holding that because the federal arbitration act 9 usc 1 et seq preempts michigans lemon law mcl 2571401 et seq the plaintiffs lemon law claim should have been resolved through binding arbitration

[Q]: Joseph F. Nascimento and his minor daughter Kendall E. Nascimento appeal pro se the district court's dismissal, pursuant to Fed.R.Civ.P. 12(b)(6), of their civil rights action seeking reversal of a Montana state court decision regarding the custody of Kendall Nascimento. We have jurisdiction pursuant to 28 U.S.C. 1291. We review de novo the district court's dismissal and affirm. See H.C. v. Koppel, 203 F.3d 610, 613 (9th Cir.2000) (<HOLDING>); see also Branson v. Nott, 62 F.3d 287, 291
Holding statements: (A) holding that a court should abstain when an exercise of jurisdiction might lead to a parallel federal regulatory review mechanism complicating state administration (B) holding that federal district courts should abstain from interfering with pending state court proceedings (C) holding that courts should only abstain under younger if the state proceedings are coercive and not remedial and citing a number of district court opinions (D) recognizing that the longstanding public policy against federal court interference with state court proceedings generally requires federal courts to abstain from involvement in state criminal proceedings (E) holding that federal courts should apply state substantive law
[A]: holding that a court should abstain when an exercise of jurisdiction might lead to a parallel federal regulatory review mechanism complicating state administration

[Q]: changes to M.R.E.s 103(a)(2), 404(a), 701-702, and 803(6) that have already taken effect through operation of M.R.E. 1102. 3 . The First, Third, Fifth, Seventh, and D.C. Circuits follow rules similar to the Ninth Circuit's formulation in Cox. See, e.g., United States v. Saccoccia, 58 F.3d 754 (1st Cir.1995); United States v. Dicker, 853 F.2d 1103, 1108-09 (3d Cir.1988); United States v. White, 569 F.2d 263, 267 (5th Cir.1978); United States v. Marzano, 537 F.2d 257, 268 (7th Cir.1976); DeLoach v. United States, 307 F.2d 653, 655 (D.C.Cir.1962) (pre-Federal Rules of Evidence case); see also United States v. Coleman, 284 F.3d 892, 894 (8th Cir.2002) (upholding police officer's testimony interpreting defendant's "drug jargon"); United States v. Peoples, 250 F.3d 630, 640-42 (8th Cir.2001) (<HOLDING>). The Sixth Circuit, however, maintains that a
Holding statements: (A) recognizing that although early interpretations of the act were narrow subsequent interpretations demonstrate that the act reaches a wide variety of deceptive commercial practices (B) holding that fbi agents testimony regarding witnesss pri or identification was admissible where nothing in the record suggested that the declarant was unavailable for reexamination after the agents testimony (C) holding that an fbi agents investigation of the written contents of a notebook that was lawfully in the possession of the fbi constituted a search that violated the defendants fourth amendment rights (D) holding that the plaintiffs ftca claims failed because the fbi agents were privileged to use reasonable force under texas law (E) holding that fbi agents interpretations of codefendants conversations were inadmissible under fedrevid 701
[A]:
recognizing that although early interpretations of the act were narrow subsequent interpretations demonstrate that the act reaches a wide variety of deceptive commercial practices