Name every way a hold ends

todo.md

@@ -204,6 +204,10 @@ and 5. Every seat ranked the session's lifecycle hardest and least wanted to mod
 
 - [ ] **Lift Locality to 7, and confirm it with a scoring run.** A run reading 7.0 or above also
       retires the #30 decision. The sub-items are what the 2026-09-28 run named, most seats first.
+- [ ] **Count an `sms` listener that throws as one giving up, as a rejection already is.** A
+      synchronous throw makes `Session.emit` return false, and `HeldMessages.offer()` then releases
+      the hold at once, so a drain stops waiting on an async listener still answering beside it.
+      Goal 2. From the stability review of #45.
 - [ ] **Shrink the `IncomingDeps` closure bag.** 16 lambdas, six of them repeated in
       `SmsHandlers`, which makes every inbound call path indirect. Two seats.