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: of other courts have concluded, outside the RICO and Clayton Act context, that "by reason of" should be read to require only "but for” rather than proximate causation. See, e.g., Gross v. FBL Fin. Servs., Inc., 557 U.S. 167, 129 S.Ct. 2343, 2350, 174 L.Ed.2d 119 (2009) ("The words ‘because of' mean ‘by reason of: on account of.’ Thus, the ordinary meaning of the ADEA's requirement that an employer took adverse action ‘because of age is that age was the ‘reason’ that the employer decided to act. To establish a disparate-treatment claim under the plain language of the ADEA, therefore, a plaintiff must prove that age was the ‘but-for’ cause of the employer’s adverse decision.” (citations omitted) (emphasis added)); Robinson Knife Mfg. Co. v. C.I.R., 600 F.3d 121, 131-32 (2d Cir. 2010) (<HOLDING>); Spirtas Co. v. Ins. Co. of Pa., 555 F.3d 647, 
 Holding statements: (A) holding that in 26 cfr  1263ale3i the language  directly benefit or are incurred by reason of boils down to a butfor causation test (B) holding that fees incurred by debtor were not in the nature of support (C) holding in an appeal from a postanswer default judgment that third prong of craddock test required appellant to offer to reimburse appellee for legal expenses he incurred in obtaining default judgment even though most of the fees incurred had not been paid (D) holding that pursuant to the eaja courts may not award expenses of an attorney that are not incurred or expended solely or exclusively in connection with the case before the court (E) holding a tribe subject to 1 a tax on the use of certain highway motor vehicles 26 usc  4481a 2 a tax on diesel fuel used in highway vehicles 26 usc  4041a 3 a tax on special fuels used in motor vehicles 26 usc  4041b and 4 a tax on manufacturing in this case a truck chassis assembled by the tribe 26 usc  4061a 4218a
Example Output: holding that fees incurred by debtor were not in the nature of support

Example Input: quantity function as elements by increasing the maximum penalty a defendant may receive, are they elements of an aggravated offense or are they sentencing factors with heightened due process requirements? See id. at 573, 575 (Hug, J., concurring) (disagreeing with the majority’s apparent conclusion that the penalty provisions of § 841(b) are not elements of the offense). The district court correctly interpreted Buckland as holding that drug type and quantity are not elements of the offense, but rather are material facts that must be submitted to the jury and proved beyond a reasonable doubt. The Buckland opinion emphasized that the relevant inquiry is not whether a penalty provision is an element, but rather whether it exposes the defendant to a longer sentence than woul (9th Cir.2002) (<HOLDING>); United States v. Minore, 292 F.3d 1109, 
 Holding statements: (A) recognizing that sentencing judges have the discretion to reject any sentencing guideline but no judge is required to do so (B) holding jury is entitled to accept the states version of the facts and reject appellants version or reject any of the witnesses testimony (C) holding that biased on buckland we must reject valensias contention that the sentencing provisions of  841 create separate crimes (D) holding that under the crimes code conspiracy and the completed substantive offense are separate crimes (E) holding the crimes merge where the jury was not asked to determine whether two assaults occurredeventhough the evidence may have been sufficient to support separate crimes
Example Output: recognizing that sentencing judges have the discretion to reject any sentencing guideline but no judge is required to do so

Example Input: the courts of this state, unless the cause of action arose out of such ownership. See 48.193(l)(c), Fla.Stat. (1991). Further, the mere execution of a guaranty generally is insufficient to subject a nonresident defendant to the jurisdiction of a Florida court. See Holton v. Prosperity Bank, 602 So'.2d 659, 662-63 (Fla. 5th DCA 1992). See also PluessStaufer Industries v. Rol-lason Engineering & Manufacturing, Inc., 635 So.2d 1070, 1073 n. 10 (Fla. 5th DCA 1994). Cf. Hamilton v. Business Assistance Consortium, Inc., 602 So.2d 619 (Fla. 3d DCA 1992). 6 . In reaching this conclusion, we did not consider any activities Nichols performed as an officer or director of the different NTS corporations, including NTS, NTS/Residential, and OLF, Inc. See Doe v. Thompson', 620 So.2d 1004 (Fla.1993) (<HOLDING>). Accord Eller v. Allen, 623 So.2d 545 (Fla. 
 Holding statements: (A) recognizing distinction between corporate officer acting on behalf of himself and corporate officer acting on behalf of his corporation (B) holding that a corporate officer acting in his or her official capacity could not tortiously interfere with a corporate contract because corporations act only through their officers and agents (C) holding that although a corporate officer is not presumed to be personally liable for corporate debts the officer may expressly bind himself or herself to be answerable for such debts (D) holding that a corporate officer signing a contract in his corporate capacity is generally not liable for damages under the contract (E) holding that determination of whether an official was acting on behalf of the state or the local government is determined by state law
Example Output:
holding that a corporate officer acting in his or her official capacity could not tortiously interfere with a corporate contract because corporations act only through their officers and agents