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.

Ex Input:
how much more of a connection to interstate commerce, if any, must be shown under a substantial rather than a de minimis standard. See Russell, 471 U.S. at 859-60 n. 4, 105 S.Ct. 2455 (suggesting in a pre-Lopez opinion that, under the Commerce Clause, Congress could only reach criminal activity " 'substantially affecting interstate commerce.' "). It is clear, however, that the direct interstate connection required by Instruction 10 is much more substantial than the indirect interstate connection articulated by the government and disapproved of by the Court in Lopez. In Lopez, the connections articulated by the government between the possession of a firearm in a local school zone and interstate commerce were, to say the least, attenuated. See Lopez, 514 U.S. at 567, 115 S.Ct. 1624 (<HOLDING>); see also Hicks, 106 F.3d at 189 (describing
Holding statements: (A) holding that a reasonable inference need not be the sole possible inference (B) holding that adverse inference rule is permissive (C) recognizing that a vital fact may not be established by piling inference upon inference (D) holding that the nonmovant need not be given the benefit of every inference but only of every reasonable inference (E) recognizing that to uphold the government contentions would require the court to pile inference upon inference

Ex Output:
holding that a reasonable inference need not be the sole possible inference

Ex Input:
511 U.S. 244, 114 S.Ct. 1483, 128 L.Ed.2d 229 (1994). In Landgraf, the Court noted that a statute only truly operates retroactively if applying it would "impair rights a party possessed when he acted, increase a party's liability for past conduct, or impose new duties with respect to transactions already completed." Id. 114 S.Ct. at 1505; see also RTC v. Ford Motor Credit Corp., 30 F.3d 1384, 1387-88 (11th Cir.1994)(analyzing retroactivity of lease repudiation damage limitation provision of FIRREA). Thus, like other courts that have analyzed similar FIRREA provisions, we must address prior banking law to determine whether application of the damage limitation provisions of 1821(e)(3) would have the retroactive effect defined in Landgraf. See, e.g., Ford Motor Credit, 30 F.3d at 1388 (<HOLDING>). We conclude that, in the Crafts' case, it
Holding statements: (A) holding that the act is not retroactive (B) holding that firreas damage limitations for repudiation of leases worked no substantive change in the law and thus their application was not retroactive (C) holding retroactive application (D) holding no retroactive application (E) recognizing that the application of a retroactive amendment is discretionary

Ex Output:
holding that the act is not retroactive

Ex Input:
they are not entitled to avoid the judicial lien. DISCUSSION Section 522(f)(1) of the Bankruptcy Code provides that the debtor may avoid most judicial liens "to the extent that such lien impairs an exemption to which the debtor would have been entitled ..." 11 U.S.C. 522(f)(1) A debtor is entitled to avoid a judicial lien that impairs a homestead exemption even if the debtors have no equity in the property. Kolich v. Antioch Laurel Veterinary Hosp. Inc., (In re Kolich), 273 B.R. 199, 204 (8th Cir. BAP 2002)(citing F.D.I.C. v. Finn (In re Finn), 211 B.R. 780, 782-84 (1st Cir. BAP 1997) and quoting H.R.Rep. No. 835, 103d Cong., 2d Sess. 45 (1994)), aff'd, 328 F.3d 406 (8th Cir.2003). See also Higgins v. Household Fin. Corp. (In re Higgins), 201 B.R. 965, 967-968 (9th Cir. BAP 1996) (<HOLDING>); In re Whitehead, 226 B.R. 539, 541
Holding statements: (A) holding that a debt or could only exempt an item of property that exceeded the exemption limit by paying the difference between the value of the property and the exemption limit to the estate (B) holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens (C) holding that a retained equity interest is property even if it has no market value (D) holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit (E) holding that debtor could not avoid a judicial lien where after accounting for unavoidable liens and mortgages he had no equity in the property and therefore no interest on which to avoid the judicial lien

Ex Output:
holding that a debt or could only exempt an item of property that exceeded the exemption limit by paying the difference between the value of the property and the exemption limit to the estate