When a court erroneously holds that it lacks jurisdiction to decide a matter, can a cursory statement that the court would deny relief on the merits if it had jurisdiction qualify as an alternative holding, as determined by the Third, Fourth, and Eleventh Circuits, or is such a statement instead merely dicta of no binding effect, as determined by the Fifth, Sixth, Seventh, Ninth, and Tenth Circuits?

Whether a cursory statement that a court would deny relief on the merits if it had jurisdiction qualifies as an alternative holding or is merely dicta