instruction:
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.
question:
of benefits in 1989 established a "pattern” of benefit increases such that the Plan's later rescission of the 1999 Benefits Increase, which was adopted ten years after the 1989 increase, violated the anti-cutback rule. We find this argument to be without merit as a matter of law. 18 . Thornton also alleges that the Board breached its fiduciary duty by favoring one class of Plan participants over another class, specifically by eliminating the 1999 Benefits Increase for pre-February 1, 1999 retirees while maintaining it for Plan participants retiring on or after that date. Thornton waived this argument on appeal, however, by waiting until his reply brief to address the issue, rather than raising it first in his opening brief. United States v. Perkins, 994 F.2d 1184, 1191 (6th Cir.1993) (<HOLDING>). 19 . 29 U.S.C. § 1132(a) states in relevant 
 Holding statements: (A) holding that arguments raised for the first time in a reply brief are forfeited (B) holding that an argument raised for the first time in a reply brief is waived (C) holding that issue raised for the first time in reply brief was waived (D) holding issues raised for the first time in a reply brief are not properly before this court (E) holding that issues not raised before the district court cannot be raised for the first time before this court
answer:
holding that arguments raised for the first time in a reply brief are forfeited


question:
was merely a voidable act. They rely on Sikes v. Global Marine, Inc., 881 F.2d 176 (5th Cir.1989), rehearing denied by 888 F.2d 1388 (5th Cir.1989), in which the Fifth Circuit found that the filing of a complaint in violation of the stay was voidable but not void. Id. at 178-79. The court reasoned that provisions of the Bankruptcy Code such as section 362(d), by giving courts the power to grant retroactive relief from a stay, indicated Congressional intent that acts in violation of a stay be simply voidable. Id. Spring Meadows, however, urges us to adopt the rule of the Ninth Circuit that any act committed in violation of an automatic stay is void. Hillis Motors, Inc. v. Hawaii Auto. Dealers Ass’n, 997 F.2d 581, 586 (9th Cir.1993); In re Schwartz, 954 F.2d 569, 571-72 (9th Cir.1992) (<HOLDING>). The circuit court found such acts void even 
 Holding statements: (A) recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect (B) holding that violations of the automatic stay are void and rejecting the reasoning of sikes (C) holding judgment in violation of automatic stay void (D) holding that the automatic stay did not bar the filing of a proof of claim where the debtor actively litigated a separate action during the pending bankruptcy proceeding because to permit the automatic stay provision to be used as a trump card played after an unfavorable result was reached  would be inconsistent with the underlying purpose of the automatic stay (E) holding that an action taken in violation of the automatic stay is void ab initio
answer:
recognizing that any action taken in violation of the automatic bankruptcy stay is void and without effect


question:
Because these hardship determinations are made in the same manner under practically identical standards and because De La Vega holds that the cancellation-of-removal hardship determination is discretionary, we join the Fourth Circuit in holding that the § 1182(i)(l) hardship determination is discretionary as well. We therefore lack jurisdiction to review this judgment. See 8 U.S.C. § 1252(a)(2)(B)®. Finally, we hold that § 106(a)(1)(A)(iii) of the REAL ID Act, 8 U.S.C. § 1252(a)(2)(D), does not affect our conclusion because the instant petition, in challenging the BIA’s discretionary extreme-hardship determination, does not raise any “constitutional claims or questions of law” within the meaning of 8 U.S.C. § 1252(a)(2)(D). See Xiao Ji Chen v. DOJ, 434 F.3d 144, 153-54 (2d Cir.2006) (<HOLDING>). For the foregoing reasons, we lack 
 Holding statements: (A) holding that the real id act gave us jurisdiction to review a criminal aliens petition for review of an order of removal raising a question of law (B) holding that adverse credibility determinations under the real id act must take into consideration the individual circumstances of the applicant (C) holding that the real id act does not restore jurisdiction over discretionary determinations (D) holding that the real id act leaves this court deprived of jurisdiction to review discretionary and factual determinations (E) holding that this court lacks jurisdiction to review the bias discretionary determinations concerning whether to grant cancellation of removal and that sjection 106 of the real id act does not override the jurisdictiondenying provision of 8 usc  1252a2b unless the petitioner raises a constitutional claim   or question  of law within the meaning of 8 usc  1252a2d
answer:

holding that the real id act gave us jurisdiction to review a criminal aliens petition for review of an order of removal raising a question of law