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: immunity defense ordinarily fails, since “a reasonably competent public official should know the law governing his conduct.” See id. (quoting Harlow, 457 U.S. at 818-19, 102 S.Ct. 2727). Thus, the aldermen are entitled to qualified immunity only if Belk’s right to free speech was not clearly established at the time of her discharge. See id. Belk was discharged in 1995. As early as 1985, the Supreme Court had found a clear First Amendment protection for public employees. “It is clearly established that a State may not discharge an employee on a basis that infringes that employee’s constitutionally protected interest in freedom of speech.” Rankin, 483 U.S. at 382, 107 S.Ct. 2891. Our own precedent evidences this principle as well. See Hafley v. Lohman, 90 F.3d 264, 267 (8th Cir.1996) (<HOLDING>); Casey, 12 F.3d at 804 (“No right is more 
 Holding statements: (A) holding that retaliatory discharge based solely on protected speech by ones spouse is actionable under the first amendment (B) recognizing retaliatory discharge tort implied by the workers compensation act (C) holding that it is clearly established that retaliation against private citizens for exercising their first amendment rights is actionable (D) recognizing the tort of retaliatory discharge (E) holding that retaliatory discharge is a clearly established first amendment violation
A: 
holding that retaliatory discharge based solely on protected speech by ones spouse is actionable under the first amendment