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.

this is irrelevant to the question of whether a loan was made to Busson-Sokolik in the first place. Finding no clear error on the question of whether the funds were in fact transferred to Busson-Sokolik and no defects in the formation of a valid contract between the parties, we affirm the finding that the sum MSOE transferred to Busson-Sokolik was a loan. 2 . “Abuse of discretion” is the clear standard for evaluating a judge’s decision to impose sanctions in a bankruptcy case. See In re Rimsat, Ltd., 212 F.3d 1039, 1046 (7th Cir.2000). While the standard for evaluating a judge’s decision not to impose sanctions in a bankruptcy case is somewhat less clear, we adopt the Sixth Circuit’s approach of using the "abuse of discretion” standard. See In re Downs, 103 F.3d 472, 480 (6th Cir.1996) (<HOLDING>). 3 . An appeal is frivolous "when the result 
 Holding statements: (A) holding that the appropriate standard of review is abuse of discretion (B) holding that the applicable standard of review for evaluating a bankruptcy courts denial of fed r bankrp 9011 sanctions is abuse of discretion and noting similar approaches taken by the ninth and tenth circuits (C) holding that the standard of review for the denial of rule 11 sanctions is governed by the law of the regional circuit (D) holding that the conclusion that the wiretap was necessary in each situation is reviewed for an abuse of discretion and bringing the tenth circuit into accordance with the authority of a majority of other circuits (E) holding that the standard of review is abuse of discretion and an appeal from denial of rule 60b relief does not bring up the underlying judgment for review
holding that the appropriate standard of review is abuse of discretion

potentially to have lost contact with family, friends, or each other. But that consequence is not “serious harm” — and warning of such a consequence is not a “threat” — under the Trafficking Victims Protection Act. In applying the Act, we must distinguish between “Dimproper threats or coercion and permissible warnings of adverse but legitimate consequences.” United States v. Bradley, 390 F.3d 145, 151 (1st Cir.2004), judgment vacated on other grounds, 545 U.S. 1101, 125 S.Ct. 2543, 162 L.Ed.2d 271 (2005); cf. Dann, 652 F.3d at 1170 (Act aims at serious trafficking and threats of dire consequences). This case involves the latter. A church is entitled to stop associating with someone who abandons it. Paul v. Watchtower Bible & Tract Soc’y of N.Y., Inc., 819 F.2d 875, 883 (9th Cir.1987) (<HOLDING>). A church may also warn that it will stop 
 Holding statements: (A) holding fourth amendment protects right to be free from arrest without probable cause (B) holding that the free exercise clause protects the practice of shunning explaining that when the members of a cjhurch no longer want to associate with someone who has abandoned them those members are free under the first amendment to make that choice (C) holding that shortterm and sporadic interference with free exercise rights does not violate the first amendment (D) holding that possession of marijuana is not protected by the free exercise clause of the first amendment (E) recognizing serious harm results when members of the legal profession engage in criminal acts which give rise to a lack of confidence by members of the public in those who are officers of the court
holding fourth amendment protects right to be free from arrest without probable cause

Alleyne error, Ellis, 868 F.3d at 1170-71, Ellis made clear that a defendant need not ”object[] during,trial to the jury instructions or the general-verdict form to preserve an Al-leyne objection." Id. at 1171. Instead, the burden is on the government to make sure the jury is properly instructed. Id. (“If the government wanted a heightened sentence under [§ 841(b)(1)(A) ], it was obliged to ensure the jury received proper jury instructions and a special-verdict form with spaces enabling the jury to find [the defendant’s] individually attributable powder and crack-cocaine amounts.”). Nevertheless, a defendant must object at some point before she is sentenced to preserve Alleyne error. Id. To be clear, however, use of the term "Alleyne" is not a necessary predicate to preservation. Id, (<HOLDING>). At oral argument, the parties argued 
 Holding statements: (A) holding that statutory maximum is twenty years when drug quantity is not charged as element of offense and found by jury beyond a reasonable doubt (B) holding that when the indictment charges that a certain minimum quantity of drugs is involved in the offense proof of that quantity is a fourth element of the offense (C) holding a defendant can preserve the type of error at issue here by invoking the applicable decision here alleyne or by claiming that the issue of drug quantity should go to the jury that an element of the offense was not proved that the judge cannot determine quantity or that quantity must be proved beyond a reasonable doubt and not by a preponderance of the evidence quotations and alteration omitted (D) holding that where the indictment charged drug quantity but drug quantity was not submitted to the jury the district court erred in using drug quantity to increase the penalty beyond the twentyyear maximum of  841b1c (E) holding that apprendi dictates that in order to authorize the imposition of a sentence exceeding the maximum allowable without a jury finding of a specific threshold drug quantity the specific threshold quantity must be treated as an element of an aggregated drug trafficking offense ie charged in the indictment and proved to the jury beyond a reasonable doubt internal footnote omitted

holding that statutory maximum is twenty years when drug quantity is not charged as element of offense and found by jury beyond a reasonable doubt