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.

Example Input: § 42-217. If, based on the proof submitted by the applicant and the field examination, the Department “is satisfied that the law has been fully complied with and that the water is being used at the place claimed and for the purpose for which it was originally intended, the [Department shall issue to such user or users a license confirming such use.” I.C. § 42-219(1). On the other hand, “[i]n the event that the [Department shall find that the applicant has not fully complied with the law and the conditions of permit, it may issue a license f ls Ground Water Dist., 141 Idaho 746, 753, 118 P.3d 78, 85 (2005) (finding that “a party is not entitled to vested rights in a water right by virtue of filing a permit application”); Hardy v. Higginson, 123 Idaho 485, 491, 849 P.2d 946, 952 (1993) (<HOLDING>). However, this Court has never considered the 
 Holding statements: (A) holding that until the state issues a certificate of appropriation any right to use the water remains inchoate (B) holding that simply because claimants had diverted the entire run of the water at issue did not give them the ability to claim a right to all the water when they could not and had not put it to beneficial use (C) holding that the legislative assembly intended the water right certificate not the permit even when followed by a beneficial use to mark the point at which a water right becomes vested (D) holding that permits only give the applicant an inchoate or contingent right to put the water to a beneficial use (E) holding that a water right is a property right created by a person appropriating unappropriated water and applying it to a beneficial use
Example Output: holding that until the state issues a certificate of appropriation any right to use the water remains inchoate

Example Input: are differences between sanctions under Rule 37(a) and substitution of counsel conditioned on payment of fees, the parallel considerations convince us that the Cunningham rationale applies here. Like Rule 37(a) sanctions, the present situation invokes concerns regarding finality, avoiding piecemeal appeals, and availability of effective appellate review.” Id. Cases from the First, Second, Third, and Fifth Circuits further support interpreting Cunningham as applying more broadly than to Rule 37(a) sanctions alone. The First Circuit recognized in Empresas Omajede, Inc. v. Bennazar-Zequeira, 213 F.3d 6, 9 n. 4 (1st Cir.2000), that Cunningham affirmed its precedents denying interlocutory appeals in the sanctions area. See, e.g., United States v. Kouri-Perez, 187 F.3d 1, 14 (1st Cir.1999) (<HOLDING>); Appeal of Licht & Semonoff 796 F.2d 564, 573 
 Holding statements: (A) holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable (B) holding sanctions pursuant to rule 26g not immediately appealable (C) holding sanctions order pursuant to district courts inherent powers not immediately appealable (D) holding such denial to be an immediately appealable collateral final order (E) holding an order of rule 37a sanctions against an attorney is immediately appealable under  1291
Example Output: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

Example Input: of conviction constitutes proof of conviction for purposes of removal proceedings. Section 1003.41(b) specifies that the certification requirement is satisfied if a copy of a record is “attested in writing by an immigration officer to be a true and correct copy of the original.” The photocopy of a document entitled “Judgment in a Criminal Case” offered at petitioner’s removal hearing was certified by one “Robert Kennedy SA 123,” but the certification did not specify that Kennedy was an “immigration officer.” For that purpose, the INS offered a form 1-213, identifying a Robert Kennedy, SA as an INS officer. There was no effort made to authenticate the 1-213, so it may have been inadmissible had a proper objection been raised. See Espinoza v. INS, 45 F.3d 308, 309-10 (9th Cir.1995) (<HOLDING>). However, Rosas Robles did not object to the 
 Holding statements: (A) holding that uncut blank green card forms constituted counterfeit instruments (B) holding that an issue must be presented to the lower court and the specific legal argument or ground to be argued on appeal must be part of that presentation if it is to be considered preserved (C) holding that immigration forms must be authenticated (D) holding in a battle of the forms inquiry that a term reserving all rights and remedies for one party did not conflict with an arbitration provision (E) recognizing that a 11 evidence must be relevant to be admissible
Example Output:
holding that uncut blank green card forms constituted counterfeit instruments

