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.

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

for the district court to grant his motion to withdraw his plea. But Harvey has not challenged the district court's ultimate finding that he was competent to stand trial based on the court's consideration of the opinions of all three psychiatrists. In light of the district court's unchallenged and supported determination that Harvey was competent to stand trial (and therefore competent to plead), Harvey cannot argue that the court committed obvious error in failing to sua sponte permit him to withdraw his plea on the basis of his "marginal competence." Nor can he claim that counsel was ineffective for failing to argue Harvey's marginal competency as a reason for withdrawing the plea. Harvey's claims related to his competency therefore fail. { 18 We affirm. 1 . The court stat Cir.2008) (<HOLDING>); United States v. Pease, 240 F.3d 938, 940-42 
 Holding statements: (A) holding defendant cannot waive claims of an illegal sentence a sentence violating terms of plea agreement an unknowing and involuntary plea and ineffective assistance of counsel (B) holding an attorneys mistaken prediction about a possible sentence does not render a defendants plea unknowing and involuntary (C) holding that a defense attorneys failure to uncover a defendants prior felony convictions and the attorneys inaccurate sentencing prediction did not render the defendants plea unknowing and involuntary because the defendant knew at the time he pleaded guilty what his sentence might be (D) holding that ineffective assistance can render a guilty plea involuntary (E) holding that an inaccurate sentencing estimate did not render a plea unknowing unintelligent or involuntary because the defendant was informed of the statutory maximum
holding defendant cannot waive claims of an illegal sentence a sentence violating terms of plea agreement an unknowing and involuntary plea and ineffective assistance of counsel

that any sentence that reasonably reflected the gravity of the petitioner’s offense would have serious consequences for the petitioner. The Court specifically recommended to the Bureau of Prisons that the petitioner be designated to the Federal Medical Center at Fort Devens, Massachusetts, although the petitioner appears to be incarcerated at another facility and has received treatment at a local hospital. The petitioner argues that this strengthens his claim that the incarceration at the MCC was unusually burdensome on him and that his attorney should have made that argument. For the reasons explained above, that is not a viable basis to grant the petition. The motion can also be read as a request to the Court to reduce his sentence because of his current medical condit h Cir.1997) (<HOLDING>). On the other hand, the Bureau of Prisons does 
 Holding statements: (A) holding the appellate court lacked jurisdiction to hear an appeal where the circuit court had the power to remand the agency decision for further proceedings (B) holding that the lower court lacked jurisdiction to hear the case because it was filed without proper authority (C) holding that the court lacked jurisdiction to hear defendants motion for reduction under section 3582c1a because the director of the bureau of prisons had not brought motion (D) holding court lacked jurisdiction to hear interlocutory appeal of denial of motion to dismiss based on qualified immunity by defendants who were not public officials (E) holding in pertinent part that this court lacked jurisdiction to hear the appeal

holding the appellate court lacked jurisdiction to hear an appeal where the circuit court had the power to remand the agency decision for further proceedings