You will be given a definition of a task first, then some input of the task.
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.

redress, there is little difference between retaliating against a person for filing a grievance, and retaliating for threatening to file one. The right to file a grievance stems from the First Amendment right to free speech and to petition the state for redress of grievances. See Noble v. Schmitt, 87 F.3d 157, 162 (6th Cir.1996). Once a prisoner makes clear his intention to resort to official channels to seek a remedy for ill treatment by a prison employee, retaliation against the prisoner by that employee implicates all the policies intended to protect the exercise of a constitutional right. It appears that the Sixth Circuit treats filing and threatening to file as categorically identical outside the prison context. See Jackson v. City of Columbus, 194 F.3d 737, 756-57 (6th Cir.1999) (<HOLDING>), abrogated on other grounds by Swierkiewicz v. 
 Holding statements: (A) holding if an employee does not speak as a citizen on a matter of public concern the employee has no first amendment cause of action based on his or her employers reaction to the speech (B) holding that an employee engages in protected activity under the first amendment when he threatens to file a lawsuit on a matter of public concern (C) recognizing a public employees first amendment right to address matters of legitimate public concern (D) holding that if the speech in question does not address a matter of public concern there is no first amendment violation (E) holding that a public employees internal memoranda raising concerns about public corruption are protected first amendment speech because they addressed a matter of public concern
Output:
holding if an employee does not speak as a citizen on a matter of public concern the employee has no first amendment cause of action based on his or her employers reaction to the speech