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.

“ ‘however inartfully pleaded,’ must be held to ‘less stringent standards than formal pleadings drafted by lawyers’ and can only be dismissed for failure to state a claim if it appears ‘beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.’” Estelle v. Gamble, 429 U.S. 97, 106, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976) (quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957)), reh’g denied, 429 U.S. 1066, 97 S.Ct. 798, 50 L.Ed.2d 785 (1977); see also Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 30 L.Ed.2d 652, reh’g denied, 405 U.S. 948, 92 S.Ct. 963, 30 L.Ed.2d 819 (1972); McDowell v. Delaware State Police, 88 F.3d 188, 189 (3d Cir.1996); United States v. Day, 969 F.2d 39, 42 (3d Cir.1992) (<HOLDING>); Lewis v. Attorney General of United States, 
 Holding statements: (A) holding that pro se pleadings are held to less stringent standards than those drafted by lawyers (B) holding that allegations of pro se complaint are held to less stringent standards than formal pleadings drafted by lawyers (C) holding that allegations in a pro se complaint are to be held to less stringent standards than formal pleadings drafted by lawyers (D) holding that the complaint submitted by a pro se plaintiff must be held to less stringent standards than formal pleadings drafted by lawyers (E) holding pro se petition cannot be held to same standard as pleadings drafted by attorneys

holding that pro se pleadings are held to less stringent standards than those drafted by lawyers