Given the task definition and input, reply with output. 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.

26C et al, 226 Or 263, 278, 360 P2d 282 (1961). In that historical context, it is clear that a plaintiffs remedies against a public body created by the state to perform functions on behalf of the state would have been understood by the drafters to have been entirely dependent on the will of the legislature. That is, in 1857, a plaintiff would not have had any absolute rights against such a body; rather, the legislature would have had the ability, when creating a public body to operate as an instrumentality of the state, to determine the scope of the public body's liability. See Hale, 308 Or at 518 (at the time of statehood, instrumentalities of the state government, performing state government functions, partook "fully of the state's immunity from suit") (citing Vendrell, 226 Or 263 (<HOLDING>), and Templeton v. Linn County, 22 Or 313, 29 P
Holding statements: (A) holding that school districts do not share in the commonwealth of pennsylvanias eleventh amendment sovereign immunity because they are not alter egos of the commonwealth (B) recognizing the districts duty of care for the protection of school children in its schools (C) recognizing application of sovereign immunity to school districts (D) recognizing that school districts may not enter agreements which are inconsistent with state law (E) recognizing that municipal corporations can include under the missouri constitution in addition to cities and towns counties school districts townships under township organization special road districts and drainage districts
holding that school districts do not share in the commonwealth of pennsylvanias eleventh amendment sovereign immunity because they are not alter egos of the commonwealth