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.

[EX Q]: situation he confronted.’ ” Id. at 367 (quoting Saucier v. Katz, 533 U.S. 194, 202, 121 S.Ct. 2151, 150 L.Ed.2d 272 (2001)). Particularly, the contours of De Boise’s right to be free from excessive force must be so sufficiently clear that a reasonable officer would know that the multiple tasings under the circumstances were a violation of that right. See Roberts v. City of Omaha, 723 F.3d 966, 972 (8th Cir.2013). Although we have determined that non-violent, non-fleeing subjects have a clearly established right to be free from the use of tasers, see Brown, 574 F.3d at 499-500, we have yet to determine whether a violent subject, acting aggressively toward officers, has a clearly established right to be free from multiple tasings. See Clark v. Ware, 873 F.Supp.2d 1117, 1123 (E.D.Mo.2012) (<HOLDING>). Indeed, in 2008, case law related to the use 
 Holding statements: (A) holding that the court could not determine as a matter of law that the repeated use of a taser on a subject that was physically resisting the police violated a clearly established right as of november 2009 (B) holding the right to record police activity on public property was not clearly established (C) holding that second element of qualified immunity test is whether the law violated was clearly established (D) holding that clearly established law is construed as supreme court or tenth circuit decisions on point or the clearly established weight of authority from other courts (E) holding that claim construction is a matter of law for the court to determine
[EX A]: holding the right to record police activity on public property was not clearly established

[EX Q]: 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
[EX A]: holding that arguments raised for the first time in a reply brief are forfeited

[EX Q]: described the manner of the attack), adopted by 2012 WL 1014821 (N.D.N.Y. Mar. 23, 2012). In alleging that his face and hand were “smashed” by Defendants Yega and Gibson, (see Compl. § II), the Complaint puts forth more than a de minimis use of force that parallels the degree of force found by other courts to be sufficiently serious under the objective prong. See, e.g., Santiago v. Westchester Cty., No. 13-CV-1886, 2014 WL 2048201, at *5 (S.D.N.Y. May 19, 2014) (finding allegations that a prison official “threw [the] [p]laintiff to the ground, twisted his arm, [and] picked him up off the ground while squeezing his throat ... lead to a plausible inference that the force inflicted was malicious and wanton”); Taylor v. Wilde, No. 11-CV-3608, 2012 WL 2860999, at *3 (E.D.N.Y. July 10, 2012) (<HOLDING>); Phelan v. Hersh, No. 10-CV-11, 2011 WL 
 Holding statements: (A) holding that the act of slamming  is objectively sufficiently serious to state a claim for relief under the eighth amendment alterations and some internal quotation marks omitted (B) recognizing that party is not permitted to use the accident of a remand to raise an issue that it could just as well have raised in the first appeal internal quotation marks and alterations omitted (C) recognizing that procedural sentencing error is harmless if the resulting sentence is not longer thanthat to which the defendant would otherwise be subject alterations and internal quotation marks omitted (D) holding that independent review is not de novo review of the constitutional issue but only a means to determine whether the state court decision is objectively unreasonable internal quotation marks omitted (E) holding that the agency did not abuse its discretion in declining to grant a continuance where the petitioner was only at the first step in a long and discretionary process and relief was speculative at best alterations and internal quotation marks omitted
[EX A]:
recognizing that party is not permitted to use the accident of a remand to raise an issue that it could just as well have raised in the first appeal internal quotation marks and alterations omitted