Given the task definition and input, reply with output. 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.

parties, Herman v. Herman, 335 Ark. 36, 977 S.W.2d 209 (1998), and the burden of showing a change in circumstances is always upon the party seeking the change in the amount of alimony. (Emphasis added.) Weeks v. Wilson, 95 Ark. App. 88, 234 S,W.3d 333 (2006) (citing Hass v. Hass, 80 Ark. App. 408, 97 S.W.3d 424 (2003)). The majority opinion specifically states that, "There is no evidence in the record to suggest that appellee needed alimony then or that she needs alimony now." (Emphasis added.) Apparently, the majority is attempting to go behind the order to determine whether or not the trial court erred in its first award of alimony. There is no authority for that proposition, and the premise is untenable. See Taylor, supra (citing Lively v. Lively, 222 Ark. 501, 261 S.W.2d 409 (1953) (<HOLDING>)). This last distinct flaw, the shifting of the
Holding statements: (A) holding that the statutory grounds for vacatur and modification of arbitration awards may not be supplemented by contract (B) holding that the statement of specific grounds in a motion for a new trial waives all other grounds not specified (C) holding that prison term following revocation of probation is a modification and part of the actual sentence imposed for the original offense (D) holding that the liberality of the original allowance cannot afford grounds for modification (E) holding that notice must state the specific grounds for the departure
holding that the statutory grounds for vacatur and modification of arbitration awards may not be supplemented by contract