Read the following excerpt from a US court opinion:
```
of protection for "free citizens” from the rights accorded pretrial detainees (under the Fourteenth Amendment) and criminal convicts (under the Eighth Amendment). See Lewis, 523 U.S. at 843, 118 S.Ct. at 1715. 4 . This statement has led at least one court to refer to Justice Rehnquist's reasoning, specifically his reliance on the Fourth Amendment’s text, as only adopted by a plurality. See Lamont v. Woods, 948 E.2d 825, 835 (2d Cir. 1991) (explaining that "[t]o a plurality of the Court, the use of the phrase ‘the people’ suggested that the Framers of the Constitution intended the amendment to apply only to ■those persons who were part of or substan tially connected to the national community”). But it does not throw Chief Justice Rehnquist’s holding,, that only aliens 329 (Fed.Cir.2008) ; United States v. Barona, 56 F.3d 1087,
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that a foreign citizen with no substantial connections to the us has no claim under the fifth amendments takings clause
B. holding that prior circuit precedent that the fifth amendments takings clause subsumes or preempts substantive due process claims was undermined by lingle
C. holding that no takings claim can arise unless a permit is denied
D. holding that taxes are not takings unless the government tries to achieve through special taxes what the takings clause of the fifth amendment forbids if done directly
E. holding that rights in a government benefits program were not vested property for purposes of the takings clause of the fifth amendment
Reply with [A, B, C, D, E] only.