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]: Erickson-Puttmann concedes that her Title VII claim against Gill fails because Gill was not her employer. See e.g., Bonomolo-Hagen v. Clay Central-Everly Community Sch. Dist., 121 F.3d 446, 447 (8th Cir.1997) (“Our Court quite recently has squarely held that supervisors may not be held individually liable under Title VII.” (citing Spencer v. Ripley County State Bank, 123 F.3d 690, 691-92 (8th Cir.1997) (per cu-riam))). Lenhardt v. Basic Inst, of Tech., Inc., 55 F.3d 377, 381 (8th Cir.1995) (noting that “[e]very circuit that has considered the issue ultimately has concluded that an employee, even one possessing supervisory authority, is not an employer upon whom liability can be imposed under Title VII.”); Smith v. St. Bernards Reg'l Med. Ctr., 19 F.3d 1254, 1255 (8th Cir. 1994) (<HOLDING>). Therefore, the court concludes that summary 
 Holding statements: (A) holding that individual employees are not liable under title vii (B) holding that individual defendants may not be held liable for violations under title vii (C) holding individual employees may be liable under title vii (D) holding that a title vii plaintiff could not hold coworkers liable in their individual capacities under title vii (E) holding that there is no individual liability under title vii
[EX A]: holding that individual employees are not liable under title vii

[EX Q]: of decision, and this is how the INS has consistently understood these terms.”); Fierro v. Reno, 217 F.3d 1, 4 (1st Cir.2000) (“[Sjubject to possible limitation, we think that the requirement of ‘legal custody’ in section 1432 should be taken presumptively to mean legal custody under the law of the state in question.”). Our decision to look to state law is consistent with our practice in other areas of federal law generally, and immigration law specifically. For example, entitlement to federal social security benefits often hinges on marital status as defined by state law. See Califano v. Jobst, 434 U.S. 47, 52-53 n. 8, 98 S.Ct. 95, 54 L.Ed.2d 228 (1977); Purganan v. Schweiker, 665 F.2d 269, 270-71 (9th Cir.1982); see also Gillett-Netting v. Barnhart, 371 F.3d 593, 599 (9th Cir.2004) (<HOLDING>). Similarly, in the immigration context, 
 Holding statements: (A) holding that the federal due process clause protects a state employee who under state law has a legitimate claim of entitlement to state employment (B) holding that statute does not provide for the adjudication by the alj of a state law breach of contract action for damages that is independent of the aljs determination of entitlement to benefits under the terms of the applicable agreement (C) holding that determination of whether an official was acting on behalf of the state or the local government is determined by state law (D) holding that whether children are legitimate for purposes of entitlement to insurance benefits is determined by state law (E) holding that applicants for welfare benefits had a property interest or legitimate claim of entitlement and were entitled to due process to protect that interest
[EX A]: holding that the federal due process clause protects a state employee who under state law has a legitimate claim of entitlement to state employment

[EX Q]: in'the amendment text. See id. at 421. We specifically addressed use of the term “protect” in the ballot title and summary, and rejected the challenger’s analogy to the use of the term “save” that was rejected in Save Our Everglades, noting that the “use of the term ‘protect’ d[id] not constitute impermissible political rhetoric or the adjudication of a fact.” Workplace Smoking, 814 So.2d at 421. We recognized that we had approved prior ballot titles and summaries containing the term “protect,” and stated that we were “unable to discern the logic as to how the application of essentially the same term” could be acceptable in one case and unacceptable in -another. Id.; see also Advisory Opinion to the Attorney Gen. re Pub. Prot. from Repeated Med. Malpractice, 880 So.2d 667 (Fla.2004) (<HOLDING>). Our analysis in the Workplace Smoking and 
 Holding statements: (A) holding that complaints regarding violation of employer policies unrelated to impermissible discrimination do not fall within the scope of title vii and therefore do not qualify for protection under the statute (B) holding that the use of excessive force does not constitute a prison condition in the ordinary sense of the term (C) holding a 1 signature requirement as within the outer boundaries of support the state may require before affording political parties ballot position (D) holding that the use of the term protection in the ballot title did not constitute impermissible political or emotional rhetoric (E) holding that the erroneous use of the term burglary in the beginning of the written jury instructions was not fundamental because any error was cured by the correct use of the term theft in the latter portion of the written instructions
[EX A]:
holding that complaints regarding violation of employer policies unrelated to impermissible discrimination do not fall within the scope of title vii and therefore do not qualify for protection under the statute