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We study nonequilibrium mode selection in dissipative exciton-polariton condensates incoherently pumped through an excitonic reservoir in the presence of pure energy relaxation. For a confined system in which a vortex mode is selected at threshold, we show that energy relaxation qualitatively changes the condensation scenario: as the pump increases, the asymptotic state evolves from a vortex condensate to a rotating mixed state and then to a ground-state condensate. Pure energy relaxation thus destabilizes condensation into excited states and promotes ground-state selection.

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