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: clause could be vitiated based on evidence of fraud "relating to the merger clause or fraud that invalidates the entire contract including the merger clause." 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs' allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 ("Fraud ... makes a contract voidable at the instance of the innocent party.") (quoting 3 Corbin, Contracts, 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs' argument conflates their tort
Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable

Output: holding that a contract made in violation of section 432070 is void rather than voidable

Input: Consider Input: was not clearly erroneous. B. Ineffective Assistance of Counsel Alternatively, Rodriguez alleges that his counsel was ineffective at rearraignment in erroneously advising him to assent to the factual basis despite his disagreements "with portions concerning various people working for him. The district court explicitly stated, however, that it was relying on the proffer, and not on the factual basis, for its finding that Rodriguez was a manager or supervisor; and this court, too, has reached its determination on the enhancement issue without reliance on the factual basis. As a result, Rodriguez was not bound by the factual basis and cannot show any prejudice arising from his attorney's performance. See Strickland v. Washington, 466 U.S. 668, 687, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984) (<HOLDING>). III. Conclusion Finding no clear error in the
Holding statements: (A) recognizing that defendant must show 1 that counsels performance was deficient and 2 that counsels errors prejudiced the defense (B) recognizing that in order to prevail on a claim of ineffective assistance of counsel a movant must show that he was prejudiced by his counsels performance (C) holding that a defendant must show prejudice resulting from counsels deficient performance to prevail on an ineffectiveassistance claim (D) holding that an alien must show error and substantial prejudice in order to prevail on a due process claim (E) holding petitioner must show prejudice to prevail on due process claim
Output: recognizing that defendant must show 1 that counsels performance was deficient and 2 that counsels errors prejudiced the defense