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.

Example Input: to foreclosure for mortgagors who are in default before initiating foreclosure proceedings pursuant to the National Housing Act, specifically 12 U.S.C. 1701-x(c)(5) (effective July 30, 2008), and pursuant to regulations promulgated by the Department of Housing and Urban Development. The Walkers contend that they were never offered counseling services or any other loss-mitigation services before the foreclosure sale. Although the record does not contain evidence indicating that the Walkers were provided counseling or other loss-mitigation services before foreclosure, this court has determined that any alleged failure to comply with loss-mitigation procedures does not constitute a valid defense to an ejectment action following a nonjudicial foreclosure. See Coleman, 104 So.3d at 206 (<HOLDING>). Thus, the alleged failure to exhaust all
Holding statements: (A) holding that a department of defense report was inadmissible (B) holding that because the department of revenue is subordinate to the board of tax review in the decision making process the department is not an adversely affected or aggrieved party having standing to petition for judicial review of the boards order reversing a decision of the department (C) holding that a failure to comply with the foreclosure statutes invalidates a foreclosure sale (D) holding that in the absence of a statute or controlling authority from our supreme court to the contrary we conclude that the failure of a foreclosing entity to comply with department of housing and urban development or department of veterans affairs lossmitigation requirements may not be raised as a defense to an ejectment action following a nonjudicial foreclosure (E) holding nonparty department of mental health had standing to appeal commitment order regarding person found not guilty by reason of insanity because department had direct interest that was affected by commitment order and because employees of the department conceivably could be held in contempt of court for failing to comply with the order
Example Output: holding that a department of defense report was inadmissible

Example Input: 879 (citations omitted). We think there is a reasonable fit here between the State's purpose of protecting society from persons who have been determined to be likely to reoffend if not placed in a secure facility and their placement in such a facility. Therefore, Garren has failed to show a substantive due process violation. VII. Vagueness. Although Garren states in a division heading in his brief that chapter 229A is vague as applied and on its face, he makes no argument in his brief in support of the contention that the statute is vague as applied to him. We deem this issue waived. See Iowa R.App.P. 14(a)(3) ("Failure in the brief to state, to argue or to cite to authority in support of an issue may be deemed waiver of that issue."); State v. Cooley, 608 N.W.2d 9, 13-14 (Iowa 2000) (<HOLDING>). Consequently, Garren is precluded from
Holding statements: (A) holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief (B) holding issue waived where matter not addressed beyond reference in heading in brief (C) holding that an issue mentioned in a brief but not addressed is waived (D) holding issues argued orally but not addressed in brief were waived (E) holding an issue listed in statement of issues on appeal but not addressed in brief is abandoned
Example Output: holding issue first addressed in appellants reply brief was not waived because it was in response to argument first presented in appellees brief

Example Input: habitat are tantamount to a proscribed "taking" under the Migratory Bird Treaty Act. Id. The court contrasted the definition of "take" under the Migratory Bird Treaty Act with the definition of "take" under the Endangered Species Act, which defines "take" broadly to include "harass" and "harm," in addition to the verbs included in the Migratory Bird Treaty Act definition. Id. at 303. The Ninth Circuit .D.Ind.1996) (declining to enjoin a proposed plan that complied with federal law, holding that indirect taking of migratory birds as a result of either habitat destruction or logging during nesting season did not fall within the Migratory Bird Treaty Act implementing regulations' definition of a "taking"); Citizens Interested in Bull Run, Inc. v. Edrington, 781 F.Supp. 1502 (D.Or.1991) (<HOLDING>). The District of New Mexico declined to apply
Holding statements: (A) recognizing that sale of a cutting of timber from devised real estate was a partial ademption (B) holding that proposed improvements to an rs 2477 route in a national preserve is subject to regulation by the national park service (C) holding a violation of the travel act (D) holding that action challenging united states forest services approval of a timber sale became moot when challenged sale was halted as a result of an administrative appeal (E) holding that diminishment of habitat for the northern spotted owl under a proposed national forest timber sale would not result in a taking in violation of the migratory bird treaty act
Example Output:
recognizing that sale of a cutting of timber from devised real estate was a partial ademption