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.

victim’s undisputed injuries, this court held that the statute required proof that the bodily injury was a foreseeable, rather than intentional, result of the rights-viólating conduct. Woodlee, 136 F.3d at 1405. At no point did this court even consider the possibility that the statute might not require proof of foreseeability at all, i.e., that the statute, imposed strict liability .on a defendant for bodily .injury resulting from his conduct. Because there is no logical distinction between the statutory language at issue in Woodlee and the language of § 841(b)(1)(E) that we are now tasked with interpreting, I believe that we are bound by Woodlee to interpret § 841(b)(1)(E) as incorporating a proximate cause requirement. See United States v. Ensminger, 174 F.3d 1143, (10th Cir.1999) (<HOLDING>). To conclude otherwise creates an 
 Holding statements: (A) holding that in the absence of an intervening supreme court decision only the en banc court may overrule a decision by a threejudge panel (B) holding that a panel may not reconsider issues decided earlier in the same case by the en banc court (C) holding that one panel of this court is bound by the precedent of an earlier panel absent en banc reconsideration or a superseding contrary decision of the supreme court (D) holding that only intervening law from the supreme court or this court sitting en banc can overrule a prior panel decision (E) holding that we are bound by prior panel opinions until they are overruled or abrogated by the supreme court or this court sitting en banc
holding that in the absence of an intervening supreme court decision only the en banc court may overrule a decision by a threejudge panel

— cannot alone support guilty verdicts. There must be some further evidence adduced indicating the defendant’s commission of the charged criminal acts. See United States v. Glenn, 312 F.3d at 69; United States v. Scheibel, 870 F.2d 818, 822 (2d Cir.1989); United States v. Johnson, 513 F.2d 819, 824 (2d Cir.1975). True enough. But these cases do not hold that, if such actus reus evidence is adduced, there is some temporal limit on the jury’s consideration of consciousness-of-guilt evidence to establish mens rea. Indeed, if flight or false exculpatory statements were indicative only of a defendant’s knowledge and intent at the time of those actions, the evidence would be irrelevant to the charged crime and properly excluded. Instead, the law admits consciousness-of-gui 209 (2d Cir.2004) (<HOLDING>). (4) The Admissions to Goldsmith Still further 
 Holding statements: (A) holding defendants false exculpatory statements admissible to show consciousness of guilt (B) recognizing that evidence of government knowledge of the defendants conduct could be part of a defendants argument that it did not knowingly submit false claims (C) holding parties to an exculpatory clause where the parties intent is clear (D) recognizing that defendants attempt to persuade a witness to make false exculpatory statements is probative of guilty knowledge and intent (E) holding that defendants attempt to mislead a client by providing it with false information was illegal witness tampering because defendant was trying to corruptly persuade or mislead the client with the intent of influencing its potential testimony before the grand jury
holding defendants false exculpatory statements admissible to show consciousness of guilt

was indeed barred (or limited) under the mandatory Guidelines regime, see Koon, 518 U.S. at 92-95, 116 S.Ct. 2035, the alternative sentencing methodology employed by his sentencing court did not treat the Guidelines as mandatory. Nor did the court exclude or limit its consideration of any category of sentencing factors. To the contrary, the court extended Simpson an open-ended invitation to make mitigating arguments, regardless of whether they would have been available under the Guidelines scheme. See Sentencing Hr’g Tr. 25-26. And Simpson responded to that invitation by citing a series of factors in support of a sente 440 (D.C.Cir.1995). In later cases, we settled on a plain error standard of review for such claims. See United States v. Draffin, 286 F.3d 606, 609 (D.C.Cir.2002) (<HOLDING>); In re Sealed Case, 204 F.3d 1170, 1173 
 Holding statements: (A) holding that the district courts denial of a downward departure was an exercise of discretion and therefore not reviewable (B) holding that failure to identify ground of admissibility limited appellate review to plain error (C) holding that we may not review a district courts refusal to grant a downward departure unless the court mistakenly believed that it lacked the authority to grant such a departure (D) holding that the failure to grant a sentencing departure on an unrequested ground is reviewable only for plain error (E) holding that an error is plain only if it is clear under current law when there is no binding precedent on point an instruction typically will not be plain error

holding that the district courts denial of a downward departure was an exercise of discretion and therefore not reviewable