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.

Example Input: cap in determining the amount of benefits another person was able to receive. Id. at 615. Although in Parisi, the child was suffering from the technical entitlement, the case stands for the proposition that a technical entitlement of zero should be counted as zero when computing family máximums. Considering that the purpose of the family maximum is to set a maximum that can be given from one wage earner’s account, Parisi complies with this purpose. IV. BY CITING PARISI, HAS PLAINTIFF RAISED A NEW ISSUE THAT IS NOT PROPERLY INCLUDED IN THIS JUDICIAL REVIEW? “[I]f petitioner wishes to preserve an issue for appeal, he must first raise it in the proper administrative forum_” Tejeda-Mata v. INS, 626 F.2d 721, 726 (9th Cir.1980); See Chung Young Chew v. Boyd, 309 F.2d 857, 861 (9th Cir.1962) (<HOLDING>). Yet, in Tejeda-Mata the court held this “in 
 Holding statements: (A) recognizing that failure to observe the required process deprives the court of jurisdiction (B) holding that the court lacked jurisdiction over the petition for review because the aliens did not appeal the ijs denial of their motion to reopen to the board resulting in failure to exhaust their administrative remedies (C) holding that partys failure to file a timely internal administrative appeal as required by regulations of the department of agriculture constituted failure to exhaust administrative remedies and precluded judicial action (D) recognizing that failure by state to provide the required certification deprives appeals court of jurisdiction over appeal (E) holding that failure to take available appeal to board of immigration appeals constitutes failure to exhaust administrative remedies and deprives the court of appeals of jurisdiction to review
Example Output: recognizing that failure to observe the required process deprives the court of jurisdiction

Example Input: 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
Example Output: holding that arguments raised for the first time in a reply brief are forfeited

Example Input: 863 (Alaska App.2006). [34] 34. Crawford, 100 P.3d at 441 (quoting Elstad, 470 U.S. at 310-11, 105 S.Ct. at 1294) (alteration in. Crawford). 35 . Elstad, 470 U.S. at 311, 105 S.Ct. at 1294 (quoting Wong Sun v. United States, 371 U.S. 471, 486, 83 S.Ct. 407, 416, 9 L.Ed.2d 441 (1963)). 36 . 903 P.2d 1090 (Alaska App.1995). [37] 37. Id. at 1098 (citations omitted). 38 . Id. at 1099 n. 4 (citing United States v. Knight, 395 F.2d 971, 975 (2nd Cir.1968)). 39 . Id. at 1098. 40 . See Moreau v. State, 588 P.2d 275, 279-80 & n. 13 (Alaska 1978); Longley v. State, 776 P.2d 339, 343-44 (Alaska App.1989). 41 . See Munson v. State, 123 P.3d 1042, 1048 (Alaska 2005) (citing Davis v. United States, 512 U.S. 452, 459, 114 S.Ct. 2350, 129 L.Ed.2d 362 (1994)). 42 . See Berghuis, 130 S.Ct. at 2259-60 (<HOLDING>); State v. Bailey, 714 S.W.2d 590, 593 
 Holding statements: (A) recognizing that davis was concerned only with the right to counsel and not the right to remain silent (B) holding that a suspect who wants to invoke his or her right to remain silent must do so unambiguously (C) holding that during police interrogation right to remain silent must be invoked unambiguously (D) holding that police may continue questioning a suspect until he unambiguously invokes his right to remain silent (E) holding that an accused must unambiguously invoke the right to remain silent
Example Output:
recognizing that davis was concerned only with the right to counsel and not the right to remain silent