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]: issue in question." Bradley Ventures, Inc. v. Farm Bureau Mut. Ins. Co. of Ark., 371 Ark. 229, 264 S.W.3d 485, 490 (2007). UAMS maintains that collateral estoppel applies to Dodson I and II, barring both of Dodson's pending claims, but our discussion is considerably narrower. First, I would set aside Dodson I because I am uncertain that the court's relevant finding was "essential to the judgment." Powell, 289 S.W.3d at 444. Second, I would set aside Count II, which is Dodson's impliedeontract claim. Importantly, Count II is premised on UAMS's conduct after Dodson II, i.e., sending Dodson bills for the embryo storage fees, and therefore cannot be precluded by the earlier chancery court decision. See Ripplin Shoals Land Co. v. U.S. Army Corps of Eng'rs, 440 F.3d 1038, 1044 (8th Cir.2006) (<HOLDING>); cf. id. at 1042 ("[R]es judicata does not
Holding statements: (A) holding that an assignment does not modify the terms of the underlying contract (B) recognizing that a final judgment may provide for a particular standard upon which to modify a final judgment (C) holding that a prior judgment regarding a permit to modify an existing bridge does not preclude a plaintiff from challenging a decision on a new application describing and a different bridge design (D) holding that district court did not abuse its discretion in refusing to permit a design defect products liability expert to submit an untimely addendum stating a new claim of failure to warn after defense expert refuted the basis of original design defect opinion (E) holding untimeliness of motion to modify medical insurance payment did not preclude motion to modify maintenance
[A]: holding that an assignment does not modify the terms of the underlying contract

[Q]: of other courts have concluded, outside the RICO and Clayton Act context, that "by reason of" should be read to require only "but for" rather than proximate causation. See, e.g., Gross v. FBL Fin. Servs., Inc., 557 U.S. 167, 129 S.Ct. 2343, 2350, 174 L.Ed.2d 119 (2009) ("The words 'because of' mean 'by reason of: on account of.' Thus, the ordinary meaning of the ADEA's requirement that an employer took adverse action 'because of age is that age was the 'reason' that the employer decided to act. To establish a disparate-treatment claim under the plain language of the ADEA, therefore, a plaintiff must prove that age was the 'but-for' cause of the employer's adverse decision." (citations omitted) (emphasis added)); Robinson Knife Mfg. Co. v. C.I.R., 600 F.3d 121, 131-32 (2d Cir. 2010) (<HOLDING>); Spirtas Co. v. Ins. Co. of Pa., 555 F.3d 647,
Holding statements: (A) holding that in 26 cfr 1263ale3i the language directly benefit or are incurred by reason of boils down to a butfor causation test (B) holding that fees incurred by debtor were not in the nature of support (C) holding in an appeal from a postanswer default judgment that third prong of craddock test required appellant to offer to reimburse appellee for legal expenses he incurred in obtaining default judgment even though most of the fees incurred had not been paid (D) holding that pursuant to the eaja courts may not award expenses of an attorney that are not incurred or expended solely or exclusively in connection with the case before the court (E) holding a tribe subject to 1 a tax on the use of certain highway motor vehicles 26 usc 4481a 2 a tax on diesel fuel used in highway vehicles 26 usc 4041a 3 a tax on special fuels used in motor vehicles 26 usc 4041b and 4 a tax on manufacturing in this case a truck chassis assembled by the tribe 26 usc 4061a 4218a
[A]: holding that fees incurred by debtor were not in the nature of support

[Q]: See Mitchell, 376 S.W.3d at 838 (quoting MacFarlane v. Burke, No. 01-10-00409-CV, 2011 WL 2503937, at *3 (Tex.App.-Houston [1st Dist.] June 23, 2011, no pet.) (mem. op.). Rabatin v. Kidd, 281 S.W.3d 558 (Tex.App.-El Paso 2008, no pet;), which Johnson relies on to support her contention that the omissions did not render her authorization ineffective, is unavailing. See id. at 562. Since the El Paso court decided that case, the Texas Supreme Court has made clear that the plaintiff must provide both the statutory notice of claim and medical authorization to toll the statute of limitations in a health care liability claim. See Carreras, 339 S.W.3d at 74; see also Nicholson v. Shinn, No. 01-07-00973-CV, 2009 WL 3152111, at *5-6 (Tex.App.Houston [1st Dist.] Oct. 1, 2009, no pet.) (mem. op.) (<HOLDING>). CONCLUSION We hold that the authorization
Holding statements: (A) holding that notice and authorization were ineffective to toll statute because release failed to include information on plaintiffs physicians for previous five years and portion requiring her to identify her treating physicians was also incomplete (B) holding the plaintiffs failure to identify an independently created right upon which her 1983 claim rested was fatal to her claim (C) holding that a defendants argument that her psr overstated the seriousness of her past conduct was not a sufficiently specific objection to the fact of her previous conviction (D) holding victim waived physicianpatient privilege by authorizing her doctor to release her medical records to the department of criminal investigation because the information contained in her medical records was no longer confidential between herself and her physician (E) holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment
[A]:
holding the plaintiffs failure to identify an independently created right upon which her 1983 claim rested was fatal to her claim