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.

Q: for relief under § 3582(c). Nor is Brown entitled to pursue his claims through § 2241. A prisoner may proceed under § 2241 if § 2255 would be “inadequate of ineffective.” 28 U.S.C. § 2255(e); Cradle v. United States ex rel. Miner, 290 F.3d 536, 538 (3d Cir.2002) (per curiam). We have held that § 2255’s “safety valve” applies only in rare circumstances, such as when an intervening change in the statute under which the petitioner was convicted renders the petitioner’s conduct non-criminal. See In re Dorsainvil, 119 F.3d 245, 251 (3d Cir. 1997). Brown has not satisfied that standard here, as he makes no allegation that he is actually innocent of the crime for which he was convicted, but instead asserts only that he is “innocent” of being a career offender. See Okereke, 307 F.3d at 120-21 (<HOLDING>). Brown must obtain a certificate of 
 Holding statements: (A) holding that prisoners challenge to his sentencing enhancement under  841 and 846 was not cognizable under  2241 (B) holding that a change in the law of sentencing does not constitute a new factor (C) holding that a  2241 petitioners claim was not cognizable under  2241 and therefore the district court lacked jurisdiction (D) holding that dorsainvil did not permit petitioner to challenge sentence via  2241 based on intervening change in sentencing law (E) holding challenge to armedcareercriminal enhancement improper under  2241

A: holding that prisoners challenge to his sentencing enhancement under  841 and 846 was not cognizable under  2241
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Q: read to give these words effect in light of the law in certain states, under the plain meaning rule, Green Tree’s position must fail. Herrin, 2007 WL 1975573, at *3. The debtor’s position is also supported by the leading commentators on the Bankruptcy Code. Collier on Bankruptcy states, “[o]nly if a mobile home or cooperative is real property under applicable non-bankruptcy law would the limitations on modification apply, even though the mobile home or cooperative is considered the debtor’s principal residence.” 8 Collier on Bankruptcy ¶ 1322.06[1][a][ii] (Lawrence P. King et al. eds., 15th ed. Revised 2005). Moreover, ignoring the term “real property” within § 1322(b)(2) is contrary to the rules of statutory interpretation. See Discover Bank v. Vaden, 396 F.3d 366, 369 (4th Cir.2005) (<HOLDING>) This Court does not believe that the result in 
 Holding statements: (A) recognizing courts must interpret statutes to give effect to all language used rendering no portion meaningless or superfluous (B) holding courts must give effect to every provision and word in a statute and avoid any interpretation that may render statutory terms meaningless or superfluous (C) holding that effect must be given if possible to every clause and word of a statute (D) holding that courts must give effect to every word when interpreting a statute (E) holding principle of statutory construction is to give effect to every clause and word of a statute

A: recognizing courts must interpret statutes to give effect to all language used rendering no portion meaningless or superfluous
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Q: injury to the debtor's estate which ultimately affect all creditors belong to trustee); Hirsch v. Arthur Andersen & Co., 72 F.3d 1085, 1094 (2d Cir.1995) (claims predicated upon the distribution of misleading documents to investors are the property of those investors, and may be asserted only by them because cause of action required proof that each individual investor relied on the misleading statement); E.F. Hutton & Co., Inc. v. Hadley, 901 F.2d 979, 985-87 (11th Cir.1990) (trustee had no standing to assert against third party claims of certain individual creditors who purchased securities through the debtor on its margin account with the third party, which subsequently sold the securities); St. Paul Fire and Marine Ins. Co. v. PepsiCo, Inc., 884 F.2d 688, 701-02 (2d Cir.1989) (<HOLDING>); Steyr-Daimler-Puch of Am. Corp. v. Pappas, 
 Holding statements: (A) holding that third party creditor had no standing to pursue alter ego claim against bankrupt subsidiarys parent company alter ego claim could be pursued by bankrupt organization under ohio law and thus alter ego claim belonged to trustee (B) holding that delaware law requires fraud injustice or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation (C) holding that the trustee could not bring a claim against sole shareholders of bankrupt corporation where shareholders had not looted or otherwise injured the corporation (D) holding that a lawsuit against a corporation that purchased assets from a bankrupt is not a claim against the debtor (E) holding that a litigant may not claim standing to assert the rights of a third party

A:
holding that delaware law requires fraud injustice or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation
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