In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Input: Consider Input: are differences between sanctions under Rule 37(a) and substitution of counsel conditioned on payment of fees, the parallel considerations convince us that the Cunningham rationale applies here. Like Rule 37(a) sanctions, the present situation invokes concerns regarding finality, avoiding piecemeal appeals, and availability of effective appellate review.” Id. Cases from the First, Second, Third, and Fifth Circuits further support interpreting Cunningham as applying more broadly than to Rule 37(a) sanctions alone. The First Circuit recognized in Empresas Omajede, Inc. v. Bennazar-Zequeira, 213 F.3d 6, 9 n. 4 (1st Cir.2000), that Cunningham affirmed its precedents denying interlocutory appeals in the sanctions area. See, e.g., United States v. Kouri-Perez, 187 F.3d 1, 14 (1st Cir.1999) (<HOLDING>); Appeal of Licht & Semonoff 796 F.2d 564, 573 
 Holding statements: (A) holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable (B) holding sanctions pursuant to rule 26g not immediately appealable (C) holding sanctions order pursuant to district courts inherent powers not immediately appealable (D) holding such denial to be an immediately appealable collateral final order (E) holding an order of rule 37a sanctions against an attorney is immediately appealable under  1291

Output: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable


Input: Consider Input: cert. denied, 506 U.S. 1071, 113 S.Ct. 1027, 122 L.Ed.2d 172 (1993). Moreover, after Lopez, courts have recognized that this de minimis standard continues in effect. United States v. Leslie, 103 F.3d 1093, 1100 (2d Cir.), cert. denied, — U.S. -, 117 S.Ct. 1713, 137 L.Ed.2d 837 (1997); United States v. Grey, 56 F.3d 1219, 1224-25 (10th Cir.1995). This is because § 1956 regulates activities that, in the aggregate, have a substantial effect on interstate commerce. See Lopez, 514 U.S. at 557, 115 S.Ct. at 1629 (stating that “where a general regulatory statute bears a substantial relation to commerce, the de minimis character of individual instances arising under that statute is of no consequence”); cf. Perez v. United States, 402 U.S. 146, 154, 91 S.Ct. 1357, 1361, 28 L.Ed.2d 686 (1971) (<HOLDING>); United States v. Staples, 85 F.3d 461, 463 
 Holding statements: (A) holding that congress may regulate purely local intrastate activities if they are part of an economic class of activities that have a substantial effect on interstate commerce (B) holding that commerce clause did not provide congress with authority to enact civil remedy provision of violence against women act inasmuch as provision was not regulation of activity that substantially affected interstate commerce (C) recognizing that  the interstate nexus requirement is satisfied by proof of a probable or potential impact on interstate commerce (D) holding that the government can satisfy the hobbs act interstate commerce requirement by showing that the robbery resulted in the closure of a business engaged in interstate commerce (E) holding that commerce clause authorizes congress to punish any particular criminal action even without proof of a relation to interstate commerce when the activity is part of a class of activities determined by congress to affect interstate commerce

Output: holding that congress may regulate purely local intrastate activities if they are part of an economic class of activities that have a substantial effect on interstate commerce


Input: Consider Input: of bribing a juror and conspiring to bribe public officials). We are, however, greatly disturbed by this "misappropriation.” 20 . Mr. DiTrapano did not comment on his authority to tell the bank falsehoods regarding his client’s intent to execute the loan documents, his client's intent to be jointly liable on the loan, and his own intent to take the loan documents to the client for the client’s signature. 21 . If Mr. DiTrapano’s law license had not already been annulled and the Court was instead deciding on an appropriate sanction, his failure to take full responsibility for his behavior would constitute an aggravating factor, potentially justifying an increase in the degree of discipline imposed. See syl. pt. 4, Lawyer Disciplinary Bd. v. Scott, 213 W.Va. 209, 579 S.E.2d 550 (2003) (<HOLDING>); Lawyer Disciplinary Bd. v. Aleshire, 230 
 Holding statements: (A) holding that the grand jury need not find nonstatutory aggravating factors (B) holding that factors increasing a defendants sentence beyond the statutory maximum of the crime charged with the exception of prior convictions must be proven beyond a reasonable doubt (C) holding that aggravating factors may justify increasing the degree of discipline imposed (D) holding that if the imposition of the death penalty depends on the existence of aggravating factors a jury must find those factors beyond a reasonable doubt (E) holding that danger must justify the degree of interference imposed


Output: holding that the grand jury need not find nonstatutory aggravating factors