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.

the future because she continues to own and operate Helping Hands and intends to remain in the childcare services profession. Docket No. 17 at 112. She posits no other basis for establishing her standing to seek prospective relief against the Secretary. Docket No. 26 at 6-9. Her status as the owner and operator of a child-care facility does not provide her with standing to seek the declaratory and injunctive relief that she seeks. Mosby v. Ligon, 418 F.3d 927, 933-934 (8th Cir.2005) (recognizing that an attorney's status as a member of the bar does not afford him or her standing to prospectively attack the implementation of the professional disciplinary procedures applicable to attorneys practicing in a particular jurisdiction); Brown v. Fauver, 819 F.2d 395, 400, n. 5 (3d Cir.1987) (<HOLDING>). Burns does not allege that she has been
Holding statements: (A) holding that counsel cannot raise his or her own ineffectiveness (B) holding that plaintiff must on his or her own initiative prove that the product reached him or her without substantial change (C) holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence (D) holding that a prisoner cannot establish his or her standing to prospectively challenge the validity of a facilitys disciplinary procedures simply by referring to his or her status as an individual incarcerated in that facility (E) holding that an expert can comply with the timing requirement if an experts research even after his or her deposition revealed that the standard of care in his or her community was the same or similar to the standard of care in the community in which he or she is testifying when the injury occurred
holding that counsel cannot raise his or her own ineffectiveness

Discipl. LEXIS 78, *9 (attorney disbursed all settlement proceeds to client less amount he retained for himself, after having been placed on notice that prior attorney claimed an in terest in any settlement funds in violation of Colo, RPC 1.15(b)). III. ANALYSIS OF SANCTION In both the Dunn and McCarthy matters, Rishel engaged in knowing conversion by obtaining funds from third parties for a stated purpose, failing to utilize the funds for that purpose, retaining the funds for an extended period of time after the third parties had withdrawn authorization, and failing to refund the amounts paid to the third parties despite their demand that he do so. The presumptive sanction for knowing conversion of the property of another is disbarment. People v. Dice, 947 P.2d 339, 340 (Colo.1997)(<HOLDING>); Motsenbocker; 926 P.2d at 577 (attorney
Holding statements: (A) holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause (B) holding that a lawyers knowing misappropriation of funds whether belonging to a client or third party warrants disbarment except in the presence of extraordinary factors of mitigation (C) holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors the attorneys clients did not suffer actual harm and the attorney established several mitigating factors (D) holding that permanent disbarment was appropriate for failure to remit 2000 in settlement funds to client and failing to answer the charges (E) recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person
holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause

interstate market, not particular interstate firms, from prohibitive or burdensome regulations."). In this case, the Referendum has prevented SDDS from operating Lonetree under the conditions and standards set forth when the legislature passed S.B. 169. However, nothing prevents SDDS from reapplying for another permit and proposing more stringent environmental safeguards. Furthermore, even if SDDS cannot operate Lonetree, the example of the Big Stone waste disposal plant demonstrates that the flow of interstate waste to South Dakota has not been prevented. The Court concludes that the incidental burden which the Referendum imposed on interstate commerce was not "clearly excessive" in comparison to the local benefits. See Clover Leaf Creamery Co., 449 U.S. at 473, 101 S.Ct. at 728-29 (<HOLDING>); Exxon, 437 U.S. at 128-29, 98 S.Ct. at 2215
Holding statements: (A) holding that summary judgment was improperly granted in view of the need for careful interpretation of the original and reissue claims in light of the specification the prosecution history and the alleged industry practice (B) holding that in 1998 the law was clearly established that excessive duration of a police dog bite and improper encouragement of a continuation of the attack by officers could constitute excessive force (C) holding that even if outofstate plastic producers were burdened relatively more heavily than the minnesota pulpwood industry the burden was not clearly excessive in view of the ecological benefits which would accrue (D) holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable (E) holding that the burden is on the plaintiff
holding that summary judgment was improperly granted in view of the need for careful interpretation of the original and reissue claims in light of the specification the prosecution history and the alleged industry practice