What does it mean when a later case indicates 'negative treatment' of a prior ruling?

• A. The later decision disapproves or narrows the earlier holding as controlling authority.
• B. The later decision fully overrules the earlier ruling with no implications.
• C. The later decision cites the earlier ruling without any modification.
• D. The later decision agrees with the earlier ruling.

Answer: (A)

Negative treatment means a later court treats an earlier ruling as not binding for the current issue, signaling disapproval or a narrowing of its authority. The later decision may critique the reasoning, distinguish the facts, or limit how broadly the prior ruling applies. That’s why this option fits best: the later decision disapproves or narrows the earlier holding as controlling authority. It’s not the same as a full overrule with no implications, nor simply citing the prior ruling without modification, nor agreeing with it.