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]: in Bowman were appointed by the court to make educational decisions for children who were wards of the district, so that the advocates effectively acted as "parents" under the IDEA. See id. Accordingly, even though they were licensed attorneys, they could not recover fees as educational advocates because they were not acting in an attorney-client capacity. See id. Pressley distinguishes from this scenario because she was employed by the Chris Anwah Law Firm, instead of being appointed by the court as an advocate. See Adewusi Deck 1. Furthermore, Pressley's work on this matter was similar to that performed by the billing attorneys. See PL's Mot., Ex. B. Yet because she is not a member of the D.C. Bar, Pressley is not entitled to attorney rates. See Dickens, 724 F.Supp.2d at 120 (<HOLDING>); Agapito v. District of Columbia, 477
Holding statements: (A) holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees (B) holding that the magistrate judge did not abuse her discretion in considering the prevailing hourly rates in the southern district of new york when awarding attorneys fees (C) holding that lexis fees are not taxable as costs but reserving ruling on whether such fees are recoverable as attorneys fees (D) holding that attorneys not admitted to the dc bar are not entitled to reimbursement but awarding fees at paralegal rates as equitable relief (E) holding that the court lacked jurisdiction to consider the appeal because it was filed before the final order awarding attorneys fees
[A]: holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees

[Q]: by Ankeny should arise rarely and therefore would be unlikely to produce a swarm of cases involving excessive force searches. Also, officials and courts are far more competent to discern which extraordinary tactics constitute excessive force than to determine in the heat of the moment "what constituted] a reasonable wait time in a particular case" before entering' usually a matter of calculating, wholly subjectively the appropriate number of seconds. Id. at 2166 (internal quotations and citations omitted). In fact, without any difficulty, we have in the past in a case remarkably similar to the one before us struck down, as constituting excessive force, specific tactics such as the ones used in the case before us. See, e.g., Boyd v. Benton County, 374 F.3d 773, 779 (9th Cir.2004) (<HOLDING>). Finally, on the cost side, the
Holding statements: (A) holding that inquiry as to whether officers are entitled to qualified immunity for use of excessive force is distinct from inquiry on the merits of the excessive force claim (B) holding officers punch of an inmate was not excessive force (C) holding that ordering police officers to use excessive force in bringing a lawyer into court was a judicial act (D) recognizing that the fourth amendment protects against the use of excessive force by police officers in carrying out an arrest (E) holding that officers had employed constitutionally excessive force by blindly throwing a flash bang grenade into an apartment occupied by five to eight individuals
[A]: holding that inquiry as to whether officers are entitled to qualified immunity for use of excessive force is distinct from inquiry on the merits of the excessive force claim

[Q]: 19, 28, 482 N.Y.S.2d 810, 818 (2d Dep't 1984); Family Court Act 439(e). Nevertheless, the issues underlying both orders were reviewable on appeal from the state court's final order dated May 30, 2001. See Matter of Ise-Smith v. Orok-Edem, 296 A.D.2d 414, 414-15, 745 N.Y.S.2d 461, 461 (2d Dep't 2002). To this extent, it appears that Edem was given a full and fair opportunity to litigate the challenged orders, which suggests that his due process claim is frivolous. We do not, however, reach that issue. Rather, we summarize the state proceedings only to illustrate that Edem's procedural due process claims are, in fact, inextricably intertwined with the state court's judgment, and thus, outside our subject matter jurisdiction. See Phifer v. City of New York, 289 F.3d 49, 57 (2d Cir.2002) (<HOLDING>). As we observed in Hoblock v. Albany County
Holding statements: (A) holding that this court may not review family court determinations that were decided after providing plaintiff a full and fair opportunity to litigate those issues (B) holding that appellate court may only review issues actually presented to and considered by the trial court (C) holding that representation issues are matters relegated to the board representation issues may not be decided by contract and thus may not be decided by an arbitrator (D) holding that the concept of collateral estoppel cannot apply when the party against whom the earlier decision is asserted did not have a full and fair opportunity to litigate that issue in the earlier case (E) holding that the petitioner who was denied further appellate review by the supreme judicial court had a full and fair opportunity to litigate his fourth amendment claim in the state trial court and appeals court and thus stone precluded federal habeas relief
[A]:
holding that appellate court may only review issues actually presented to and considered by the trial court