Read the following excerpt from a US court opinion:
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due process requirements. And that question is not before us now. As such, I cannot agree that a procedure created and used for § 1226(a) detainees tells us anything about the constitutional adequacy of the procedures governing unreasonably prolonged detention under § 1226(c). Our decision regarding what due process requires in this context perhaps should bear upon the protections owed to § 1226(a) detainees, not the other way around. Indeed, the Ninth Circuit, which has adopted a clear and convincing evidence standard for § 1226(c) detainees, appears to have adopted the same standard for § 1226(a) detainees. See Rodriguez, 804 F.3d at 1087 (applying a clear and convincing evidence standard to a class comprised of aliens detained under § 1226(a) and (c)); Singh, 638 F.3d at 1205 . Significant deprivations of liberty warrant
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the clear and convincing evidentiary standard applies to section 101 challenges
B. holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied
C. holding that the clear and convincing evidence standard of proof applies in casascastrillon 535 f3d at 948  1226a  bond hearings
D. holding that the clear and convincing evidence standard of proof applicable in fraud actions does not apply to the proof of misrepresentations under ors 743612
E. holding that in a proceeding to terminate parental rights the preponderance of the evidence standard of proof violates the due process clause and that due process requires at least a clear and convincing evidence standard
Reply with [A, B, C, D, E] only.