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.

of action to be known as “civil action”[,]’ the statute authorizing foreclosures by action compelled such suits to be brought in equity”) (some brackets added and some in original); Bank of Hawaii v. Davis Radio Sales and Service, Inc., 6 Haw.App. 469, 480-81, 727 P.2d 419, 427 (1986). A complaint in equity is an appeal to the exercise of the equity court’s sound discretion, Fleming v. Napili Kai, Ltd., 50 Haw. 66, 430 P.2d 316 (1967). Equity jurisprudence is not bound by strict rules of law, but can mold its decree “to do justice,” id.,' and a court of equity, once having assumed jurisdiction, may retain the case to afford complete relief. Tugaeff v. Tugaeff, 42 Haw. 455 (1958). Id. at 481, 727 P.2d at 427. See also Forte v. Nolfi, 25 Cal.App.3d 656, 692, 102 Cal.Rptr. 455, 479 (1972) (<HOLDING>). Accordingly, the circuit court had the power 
 Holding statements: (A) holding that mers is capable of being a valid beneficiary of a deed of trust and that while entitlement to enforce both the deed of trust and the promissory note is required to foreclose nothing requires those documents to be unified from the point of inception of the loan (B) holding that a promissory note is not enforceable against a party who signed the deed of trust but did not sign the promissory note inasmuch as promissory notes and deeds of trust are separate legal documents with unique purposes (C) holding that while nondebtor purchase money deed of trust can be described as part of the same transaction by which the buyer acquired debtors real property that does not elevate the deed of trust to status of something under a plan confirmed (D) holding that when note and deed of trust were null and void and of no legal effect because of forgery assignee of note and deed of trust nevertheless had equitable lien upon property for value of construction work for which note and deed of trust were given (E) holding that a beneficiary under a deed of trust was entitled to reformation of the grantors deed
holding that mers is capable of being a valid beneficiary of a deed of trust and that while entitlement to enforce both the deed of trust and the promissory note is required to foreclose nothing requires those documents to be unified from the point of inception of the loan

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
holding that arguments raised for the first time in a reply brief are forfeited

States, 418 U.S. 87, 117, 94 S.Ct. 2887, 41 L.Ed.2d 590 (1974) (internal citations omitted). A court “read[s] an [indictment] as a whole” and “construefs] the allegations in a practical sense, with all necessary implications.” Barker, 985 F.2d at 1125 (internal citations omitted). II. Section 922(k) is a Valid Exercise of Congress’s Authority Under the Commerce Clause Defendant Colon-Quiles argues that section 922(k) is an invalid exercise of Congress’s authority under the Commerce Clause because the activity that it prohibits does not have a substantial effect upon interstate commerce. Section 922(k) reads, in part, as follows: “[i]t shall be unlawful for any person ... to possess or receive any firearm which has had the importer’s or manufacturer’s s 1904, 146 L.Ed.2d 902 (2000) (<HOLDING>); and United States v. Morrison, 529 U.S. 598, 
 Holding statements: (A) holding that a determination of whether the defendants actions constituted a taking under the louisiana constitution does not implicate any issues of federal law and thus does not provides a basis for a federal district court to exercise federal subject matter jurisdiction (B) holding that restaurant that bought and sold products produced outside of state satisfied interstate commerce requirement for federal arson statute (C) holding under the circumstances that a criminal proceeding does not qualify as an alternate remedy under the federal fca (D) holding that application of federal arson statute to a private home would federalize a typically state crime and thereby significantly change  the federalstate balance in the prosecution of crimes (E) holding that arson of an owneroccupied residence not used for any commercial purpose does not qualify as property used in commerce and is not subject to federal prosecution under federal arson statute

holding that a determination of whether the defendants actions constituted a taking under the louisiana constitution does not implicate any issues of federal law and thus does not provides a basis for a federal district court to exercise federal subject matter jurisdiction