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: Consider Input: Brown's argument that she was speaking as a citizen is supported by the fact that ordinary citizens may similarly report public misconduct to the Auditors. See Conn. Gen. Stat. 4-61dd (conferring right to file reports with Auditors on "any person"). The existence of a civilian analogue to Brown's conduct strengthens her allegations that her speech was as a citizen and thus protected by the First Amendment. See Matthews I, 779 F.3d at 176. The instant case is not similar to other cases of its type that were dismissed at the motion to dismiss stage. In many of those cases, the plaintiff-employee had made an admission that the alleged speech was made, at least in part, pursuant to his or her official duties. See Matthews v. Lynch, 483 Fed.Appx. 624, 626 (2d Cir. 2012) (Matthews III) (<HOLDING>); Anemone, 629 F.3d at 116. Here, there is no
Holding statements: (A) holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel (B) holding that a plaintiff did not complain to the eeoc pursuant to official duties but rather as a citizen (C) holding that pursuant to garcetti plaintiffs speech made in the course of his official duties was unprotected as a matter of law (D) holding that speech was pursuant to official duties because plaintiff conceded at oral argument that as an internal affairs officer he had a broad responsibility to investigate and report police misconduct (E) holding police officer is a public official

Output: holding that rule was not violated where officer stated he made a report but was unable to find it because there was no report to tender to counsel

Input: Consider Input: options," including by streamlining communication between the distressed borrower and foreclosing party. See Assemb. B. 278, 2011-2012 Leg., Reg. Sess. (Cal. 2012); S.B. 900, 2011-2012 Leg., Reg. Sess. (Cal. 2012). There has been a wave of litigation in state and federal courts challenging various aspects of the MERS System. Almost all of the relevant law is state rather than federal. The results under state law have been inconsistent. See Weber, supra, at 246-56 (cataloguing the "schizophrenic position of state courts" on issues relating to the MERS System). Some state supreme courts have upheld the MERS System on issues ranging from foreclosure authority to recording requirements. See, e.g., Renshaw v. Mortg. Elec. Registration Sys., Inc., 155 Idaho 656, 315 P.3d 844, 846-47 (2013) (<HOLDING>); Jackson v. Mortg. Elec. Registration Sys.,
Holding statements: (A) holding that mers lacked standing to foreclose as the lenders nominee (B) holding that because mers receives no payments on the debt it is not the beneficiary even though it is so designated in the deed of trust (C) holding that mers is an ineligible beneficiary within the terms of the washington deed of trust act if it never held the promissory note or other debt instrument secured by the deed of trust and that characterizing mers as the beneficiary has the capacity to deceive and may give rise to an action under the consumer protection act (D) holding that mers may be a beneficiary as nominee for the lender that assignments of the deed of trust between mers members need not be recorded that mers was not liable to the borrower in negligence and that the idaho consumer protection act did not provide a cause of action to the borrower (E) holding that mers was not the beneficiary of a deed of trust under the oregon trust deed act absent conveyance to mers of the beneficial right to repayment and that mers could not hold or transfer legal title to the deed as the lenders nominee

Output: holding that mers lacked standing to foreclose as the lenders nominee

Input: Consider Input: subject to forfeiture, without regard to the location of that property. This Court has jurisdiction pursuant to 28 U.S.C. 1291 (2000). The Williams action, also an in person-am suit, was filed in the District Court for the Southern District of New York pursuant to that court's diversity jurisdiction under 28 U.S.C 1332 (2000). The Receiver for NHLIC brought suit against persons and entities, not property, seeking recovery of funds believed to have been stolen from NHLIC. The fact that the court in Williams is exercising control over the proceeds from the sale of the Center Mall property does not transform that suit into an in rem proceeding or alter the basis of the court's jurisdiction. See United States v. $174,206.00 in United States Currency, 320 F.3d 658, 661 (6th Cir.2003) (<HOLDING>). Ill The Government contends that this Court
Holding statements: (A) holding that the district court properly exercised jurisdiction over a criminal forfeiture action where a state court in a related state court forfeiture proceeding had in personam jurisdiction over the same currency subject to forfeiture (B) holding that double jeopardy clause did not apply to forfeiture proceeding before the court (C) recognizing criminal forfeiture as an aspect of punishment (D) recognizing that the hallmark of an in personam forfeiture proceeding is one where the government proceeds directly against the person (E) holding that the superior court had no jurisdiction over the division of marital property when the district court had properly invoked jurisdiction over the property
Output: holding that double jeopardy clause did not apply to forfeiture proceeding before the court