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: v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (2007). Kyler Road Home Charles first argues on appeal that the circuit court erred by not awarding him an interest in the home on Kyler Road. Although he acknowledges that Myra had acquired this property prior to the marriage, he asserts that he is entitled to an interest in the home because | ^marital funds were used to reduce the debt on the properly and to make improvements. Our definition of marital properly excludes property acquired before the marriage. Ark.Code Ann. 9-12-315(b)(1) (Repl.2009). However, we have long held that a non-owning spouse is entitled to some benefit when marital funds have been expended to improve or reduce the debt on the other spouse's nonmarital property. See Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (1993) (<HOLDING>); Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d
Holding statements: (A) holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property (B) holding that assets acquired subsequent to separation are not considered marital property absent evidence that spouse used marital property to obtain them (C) holding that separate property may become marital property if spouse donates it to marital unit with intent at time of donation that property become marital (D) holding that the trial court erred in finding that marital property was the former wifes separate property based on a nonseparation agreement in which the former husband purported to relinquish any interest in the marital property (E) holding that circuit court erred in failing to consider that marital property in the form of marital earnings was used to pay debt against nonmarital property

Output: holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property

Input: Consider Input: the future because she continues to own and operate Helping Hands and intends to remain in the childcare services profession. Docket No. 17 at 112. She posits no other basis for establishing her standing to seek prospective relief against the Secretary. Docket No. 26 at 6-9. Her status as the owner and operator of a child-care facility does not provide her with standing to seek the declaratory and injunctive relief that she seeks. Mosby v. Ligon, 418 F.3d 927, 933-934 (8th Cir.2005) (recognizing that an attorney's status as a member of the bar does not afford him or her standing to prospectively attack the implementation of the professional disciplinary procedures applicable to attorneys practicing in a particular jurisdiction); Brown v. Fauver, 819 F.2d 395, 400, n. 5 (3d Cir.1987) (<HOLDING>). Burns does not allege that she has been
Holding statements: (A) holding that counsel cannot raise his or her own ineffectiveness (B) holding that plaintiff must on his or her own initiative prove that the product reached him or her without substantial change (C) holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence (D) holding that a prisoner cannot establish his or her standing to prospectively challenge the validity of a facilitys disciplinary procedures simply by referring to his or her status as an individual incarcerated in that facility (E) holding that an expert can comply with the timing requirement if an experts research even after his or her deposition revealed that the standard of care in his or her community was the same or similar to the standard of care in the community in which he or she is testifying when the injury occurred

Output: holding that counsel cannot raise his or her own ineffectiveness

Input: Consider Input: (explaining that Habeas Counsel was "finally ... able to retrieve [the] materials from prior counsel"; that "[t]he boxes were a mess"; and that Habeas Counsel was "on trial for several weeks and could not devote needed attention to this project" (emphases added)).) And after retrieving and reorganizing the materials, Habeas Counsel allowed another forty-seven days to elapse before he sent the Coram Nobis Petition on October 16, 2006-notwithstanding when it was actually stamped filed. Cf. Lee v. Portuondo, No. 02-CV-3990, 2008 WL 22173078, at *2 (E.D.N.Y. Aug. 29, 2003) (concluding that the petitioner's three attempts to obtain files in the one-year limitations period did not constitute a diligent effort); Lewis v. Walsh, No. 03-CV-1932, 2003 WL 21729840, at *3 (S.D.N.Y. July 25, 2003) (<HOLDING>). But even assuming that Petitioner's and
Holding statements: (A) holding that agency demand letters are not suits (B) holding demand letter written prior to and during litigation absolutely privileged (C) holding that petitioners sending sporadic letters requesting documents written with lengthy delays between each letter was not a sufficiently diligent effort (D) holding that documents did not substantially comply where copies of letter of credit and promissory note were submitted and letter of credit required originals (E) holding defendants were entitled to a decision on the merits on rule 11 sanctions where they substantially complied with rule 11c1a by sending a letter rather than serving a motion
Output: holding that agency demand letters are not suits