Read the following excerpt from a US court opinion:
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— • and the majority errs in dismissing it. III. The majority notes that “lower courts have issued conflicting and confusing opinions” under Elrod and Branti (internal quotation mark omitted). At least some of these inconsistencies can be laid at the feet of courts, like today’s majority, that are simply antagonistic to the Supreme Court’s Elrod-Branti jurisprudence. Even if inferior courts believe that Supreme Court holdings are ill-advised, they are not at liberty to ignore those holdings. Time and again, inferior federal courts have sought to circumvent the Elrod-Branti jurisprudence by refusing to apply it to decisions regarding promotions, transfers, or dealings with independent contractors. See, e.g., O’Hare Truck Service, Inc. v. City of Northlake, 47 F.3d 883 (7th Cir.1995) ; Horn v. Kean, 796 F.2d 668 (3d Cir.1986) (en
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What is the most suitable continuation to the opinion? Your options are:
A. holding that apprendi does not apply retroactively
B. holding that apprendi does not apply on collateral review
C. holding that  1447c does not apply to counsel
D. holding elrodbranti does not apply to independent contractors
E. holding that title ii does not apply to the states
Reply with [A, B, C, D, E] only.