Instructions: 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.
Input: as dictum, we are obligated " 'to accord great deference to Supreme Court dicta,' absent a change in the legal landscape." Newdow v. Peterson, 753 F.3d 105, 108 n.3 (2d Cir. 2014) (quoting United States v. Colasuonno, 697 F.3d 164, 179 (2d Cir. 2012)). Harris has demonstrated no such change, and certainly none warranting a plain error conclusion. See United States v. Wagner-Dano, 679 F.3d 83, 94 (2d Cir. 2012) ("'The burden of establishing entitlement to relief for plain error is on the defendant claiming it.' " (brackets omitted) (quoting United States v. Dominguez Benitez, 542 U.S. 74, 82, 124 S.Ct. 2333, 159 L.Ed.2d 157 (2004))). If anything, the post-Johnson landscape in this circuit suggests the contrary. See, e.g., United States v. Parisi, 821 F.3d 343, 347-48 (2d Cir. 2016) (<HOLDING>); United States v. Vargas, 564 F.3d 618, 623-24
Holding statements: (A) holding that change of circumstances is not prerequisite to additional 3583e2 modification (B) recognizing that injury is a prerequisite to liability (C) holding that a coa is a jurisdictional prerequisite (D) holding that a showing of a change in circumstances that is or is likely to be beneficial to the child may also warrant a change in custody (E) holding that a custodial parents move to a foreign state without more is not a substantial change of circumstances that would support a modification of custody
Output:
recognizing that injury is a prerequisite to liability