With no explanation, chose the best option from "A", "B", "C" or "D". it is returned by a grand jury at a subsequent term of court. Tatum, 505 S.W.2d at 550. In Tatum, the defendant was arrested during the August 1970 grand jury term and not indicted until the August 1972 term. The defendant claimed that the indictment should be dismissed based on article 32.01. The Texas Court of Criminal Appeals held that the trial court properly denied the defendant’s request because article 32.01 has no application once an indictment is returned, even though it is returned by a grand jury at a subsequent term of court. Id. The court further held that the defendant’s proper remedy would have been to seek dismissal before the indictment was issued. Id. Courts which have followed Tatum include Wilkinson v. State, 899 S.W.2d 20 (Tex.App.—San Antonio 1995, pet. ref'd) (<HOLDING>); Uptergrove v. State, 881 S.W.2d 529

A: holding that a party must obtain a distinct ruling on an issue in order to raise it on appeal
B: holding that in ruling on a motion for summary judgment the trial court is limited to the grounds raised in the motion
C: holding that the failure to obtain a ruling on a motion for new trial waives the issues raised for appellate review
D: holding that the key for the accused but unindicted is to seek and obtain a ruling on an article 3201 motion prior to indictment
D.