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.

(1986) (relying on section 45(1) and comment a). 24 . See e.g., United States R.R. Ret. Bd. v. Fritz, 449 U.S. 166, 174 (1980) (“railroad [retirement] benefits are not contractual and may be altered or even eliminated at any time”); Devlin v. Transportation Communications Int’l Union, 173 F.3d 94, 103 (2nd Cir. 1999) (a claim to vested welfare benefits is contradicted by the ... unambiguous reservation in the plan documents of its right to amend the plan”); International Union, United Auto., Aerospace and Agric. Implement Workers of Amer. v. BVR Liquidating Inc., 190 F.3d 768, 773 (6th Cir. 1999) (“the inclusion of a ‘reservation of rights’ provision establishes that there was no intent for benefits to vest”); McGrath v. Rhode Island Retirement Bd., 88 F.3d 12, 17-18 (1st Cir. 1998) (<HOLDING>); In re Unisys Corp. Retiree Medical Benefit 
 Holding statements: (A) holding that performance of employment services constituted acceptance of the offer of participation in bonus plan and a binding unilateral contract was thereby formed (B) recognizing that generally    with supposed unilateral contracts  if the offeror expressly reserves the power to revoke the offer until the offerees performance is complete then the offer is illusory and cannot give rise to a unilateral contract but noting exceptions (C) holding that the offerors signature on the offerees conditional acceptance bound the offeror to all the terms therein (D) holding that an offer to donate cannot be an offer to sell (E) holding that a written offer accepted by parol may constitute a sufficient memorandum of the contract provided the person making the offer is the party to be charged
holding that performance of employment services constituted acceptance of the offer of participation in bonus plan and a binding unilateral contract was thereby formed

acted outside their jurisdiction. In sum, none of Pasiewicz’s arguments show that Sandahl and Henning violated the Constitution when they arrested him. They and the other officers (Johnson in particular) certainly could have, and we think should have, proceeded with more caution. They get no commendation ribbons for the way they handled this case. Pasiewicz’s claim against the forest preserve district (even assuming it’s a suable entity) for failure to train or supervise its officers properly regarding the laws of search, seizure, and jurisdiction is a born loser. Because the officers did not violate Pasiewicz’s constitutional rights, he did not suffer constitutional injury. Accordingly, under City of Los Angeles v. Heller, 475 U.S. 796, 799, 106 S.Ct. 1571, 89 L.Ed. 1412 (D.D.C.1983) (<HOLDING>), it is worth pointing out that Ross involved 
 Holding statements: (A) holding that knockandannounce principle is an element of the fourth amendment reasonableness inquiry because we have little doubt that the framers of the fourth amendment thought that the method of an officers entry into a dwelling was among the factors to be considered in assessing the reasonableness of a search and seizure (B) holding that an arrest made by an officer outside his jurisdiction does not violate the fourth amendment (C) holding that whether an officers force was reasonable must be analyzed under the reasonableness standard of the fourth amendment (D) holding that a search incident to a lawful arrest does not violate the fourth amendment (E) holding that the concept of reasonableness in the fourth amendment logically presupposes an exercise of lawful authority by a police officer
holding that knockandannounce principle is an element of the fourth amendment reasonableness inquiry because we have little doubt that the framers of the fourth amendment thought that the method of an officers entry into a dwelling was among the factors to be considered in assessing the reasonableness of a search and seizure

I believe Alvarez has established enough facts to survive summary judgment. That is because “[o]nce there is evidence of improper conduct and subjective offense, the determination of whether the conduct rose to the level of abuse is largely in the hands of the jury.” Howard v. Burns Bros., Inc., 149 F.3d 835, 840 (8th Cir.1998). I recognize that the hostile environment factor is difficult to analyze in light of our varying jurisprudence. Compare Duncan v. Gen. Motors Corp., 300 F.3d 928 (8th Cir.2002) (finding that a single request for a relationship, four or five isolated touching incidents, a request to draw a phallic symbol and teasing in the form of a gender-based poster were not severe enough to meet this element); with Eich v. Bd. of Regents, 350 F.3d 752 (8th Cir.2003) (<HOLDING>). However, “[ejach case must stand on its own 
 Holding statements: (A) holding that conduct of supervisor who grabbed plaintiff on the buttocks and made suggestive comments while she was conversing with another employee was not sufficiently severe or pervasive to alter a term or condition of plaintiffs employment (B) recognizing that a plaintiff can demonstrate that samesex harassment is because of sex by showing that the conduct was motivated by the coworkers sexual desire for persons of the same sex (C) holding that several touching incidents standing behind the plaintiff simulating a sex act and another incident of simulating a sex act were severe or pervasive enough to affect a term or condition of employment (D) holding that conduct was not sufficiently severe or pervasive where over twoweek period a coworker stood behind the plaintiff to create physical contact surreptitiously looked at the plaintiffs genitals in the restroom and engaged in unwanted touching (E) holding that conduct that a jury finds to be based on sex and not motivated by nondiscriminatory reasons cannot later be found by a district court to lack an intent to discriminate on the basis of sex

holding that conduct of supervisor who grabbed plaintiff on the buttocks and made suggestive comments while she was conversing with another employee was not sufficiently severe or pervasive to alter a term or condition of plaintiffs employment