Dropdown Eval exception : getPhpOptions() Only variables should be assigned by reference

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I have a Fabrik Dropdown Element with the following code in the 'Advanced' tab:

$options[] = JHTML::_('select.option', 'please_select', 'Please Select');
return $options;

And I am getting the following message:
Eval exception : getPhpOptions() : Only variables should be assigned by reference

This only appears with Debug enabled in Fabrik options.

Anyone have any ideas on this?
 
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