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: for [her] employer! ] to operate efficiently and effectively." Id. at 418-19, 126 S.Ct. 1951. The point of this inquiry, then, is "both to promote the individual and societal interests that are served when employees speak as citizens on matters of public concern and to respect the needs of government employers attempting to perform their im portant public functions." Id. at 420, 126 S.Ct. 1951. With that premise as a backdrop, the Supreme Court held that "when public employees make statements pursuant to their official duties, the employees are not speaking as citizens for First Amendment purposes, and the Constitution does not insulate their communications from employer discipline." Id. at 421, 126 S.Ct. 1951; see also Haynes v. City of Circleville, 474 F.3d 357, 364-65 (6th Cir.2007) (<HOLDING>). Thus, Garcetti and its Sixth Circuit progeny
Holding statements: (A) holding that the plaintiffs speech was not constitutionally protected because it was made in his official capacity and there was simply no evidence that he was speaking as a citizen on a matter of public concern (B) holding that pursuant to garcetti plaintiffs speech made in the course of his official duties was unprotected as a matter of law (C) holding that a teachers complaint to school authorities that her principal had instructed her to make improper changes in her own students grades was unprotected because it was made pursuant to her official duties (D) holding that garcetti barred claims involving speech not necessarily required by the plaintiffs job duties but nevertheless related to his job duties (E) holding that when protected speech is inextricable from unprotected speech the court will treat the entire message as protected

Output: holding that the plaintiffs speech was not constitutionally protected because it was made in his official capacity and there was simply no evidence that he was speaking as a citizen on a matter of public concern

Input: Consider Input: and therefore, need only show that the trial court abused its discretion by denying his challenges for cause. "[A] challenge for cause should be granted, even when a prospective juror declares his ability to remain impartial, if the juror's responses as a whole reveal facts from which bias, prejudice or inability to render judgment according to law may be reasonably implied." State v. Hallal, 557 So.2d 1388, 1389-90 (La.1990). The proper standard for determining when a prospective juror may be excluded for cause because of his views on capital punishment is whether the juror's views would "prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath." Witherspoon v. Illinois, 391 U.S. 510, 88 S.Ct. 1770, 20 L.Ed.2d 776 (1968) (<HOLDING>); see also Wainwright v. Witt, 469 U.S. 412,
Holding statements: (A) holding that graham which prohibited the imposition of a life without parole sentence on a juvenile offender who did not commit homicide does not apply to a lengthy termofyears sentence that might constitute a de facto life sentence (B) holding that an effective life sentence of fortyfive years for seconddegree forgery was excessive and that a life sentence was cruel and unusual in violation of the eighth amendment (C) holding that a prospective juror who would vote automatically for a life sentence is properly excluded (D) holding life sentence mandatory under 21 usc 841b and district court could not depart from the mandatory life sentence unless government made a motion (E) holding that time excluded from a speedy trial clock for pretrial motion preparation is not automatically excluded under 3161h1 but may only be excluded when a court makes appropriate reasonableness findings under 3161h7

Output: holding that graham which prohibited the imposition of a life without parole sentence on a juvenile offender who did not commit homicide does not apply to a lengthy termofyears sentence that might constitute a de facto life sentence

Input: Consider Input: we hold that Defendant's employee handbook does not constitute an implied waiver of sovereign immunity. Participation in New Mexico's Workers' Compensation Program {17} Plaintiff urges the Court to hold that Defendant's voluntary participation in New Mexico's workers' compensation program serves as a waiver of immunity. Plaintiff makes this argument without citing to any authority or providing any substantive argument in support of her contention. {18} A waiver of sovereign immunity cannot be implied. Santa Clara Pueblo, 436 U.S. at 58, 98 S.Ct. 1670. Thus, we conclude that waivers of sovereign immunity cannot be created by implication through activities such as participation in the state's workers' compensation program. See Webb v. Paragon Casino, 872 So.2d 641, 646 (La.Ct.App.2004) (<HOLDING>). Inconsistent Waivers in Other Business
Holding statements: (A) holding that an indian tribe is subject to suit only where congress has authorized the suit or the tribe has waived its immunity (B) holding that an official of an indian tribe should be stripped of his authority and corresponding immunity to act on behalf of his tribe whenever he exercises a power his tribe was powerless to convey to him (C) holding that state did not have jurisdiction over tribe where tribe paid into workers compensation program but had not waived sovereign immunity (D) holding that offreservation casino owned and operated by tribe was arm of the tribe and therefore was entitled to sovereign immunity (E) holding that as a matter of federal law an indian tribe is subject to suit only where congress has authorized the suit or the tribe has waived its immunity
Output: holding that an indian tribe is subject to suit only where congress has authorized the suit or the tribe has waived its immunity