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: 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
Example Output: holding that individual employees are not liable under title vii

Example Input: hearing are binding on the appellate courts if supported by competent evidence. State v. Brooks, 337 N.C. 132, 140, 446 S.E.2d 579, 585 (1994). A trial court’s conclusions of law are reviewed de novo on appeal. State v. Kincaid, 147 N.C. App. 94, 97, 555 S.E.2d 294, 297 (2001). In the present case, the trial court made the following relevant findings of fact: that on or about July 6, 2004 . . . Officer Henderson, a 27 year veteran of the Burlington Police Dept, had received a call of a suspicious activity at Coy’s Exxon on the comer of Graham-Hopedale Rd. and N. Church St. That location has had numerous calls for shopliftingy fights[,] and other activity. Also there is numerous gang and graffiti act S.E.2d 412, 418 (2004), disc. review denied, 359 N.C. 283, 610 S.E.2d 208 (2005) (<HOLDING>). The State argues “ [i]t is clear from the 
 Holding statements: (A) holding reasonable and articulable suspicion existed to support an investigatory stop of a vehicle where the defendant and driver were observed loitering at a closed shopping center shortly before midnight no other vehicles were in the parking lot and the two men abruptly and hurriedly returned to their vehicle which was parked out of general public view (B) holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes (C) holding that officer had reasonable suspicion to stop a vehicle when confidential informant personally observed the vehicle provided a description of the vehicle and its direction detailed the basis for her suspicion that the vehicle was engaged in illegal activity and had previously given reliable information that led to the successful apprehension of individuals engaged in various criminal activity (D) holding reasonable and articulable suspicion existed to support the investigatory stop of a vehicle in view of the time of day and the officers prior knowledge of reports of criminal activity in the area (E) holding that a mere parking violation justified the investigatory stop of choudrys vehicle
Example Output: holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes

Example Input: file were prepared in anticipation of litigation. The trial court should consider the nature of the requested documents, the reason the documents were prepared, the relationship between the preparer of the document and the party seeking its protection from discovery, the relationship between the litigating parties, and any other facts relevant to the issue. See Haynes, 597 So.2d at 619. The discoverability of such documents may differ depending on the circumstances of the case. Documents obtained by an insurer where its own insured is the claimant against it (first-party claim) may well be treated differently from documents obtained by an insurer from its insured where the potential claimant is a third party. See Beck v. Farmers Ins. Exch., 701 P.2d 795, 798 n. 2, 799-800 (Utah 1985) (<HOLDING>); accord Campbell v. State Farm Mut. Auto. Ins. 
 Holding statements: (A) holding that the governments cooperation with a thirdparty is not sufficient to establish a thirdparty beneficiary relationship (B) holding that a thirdparty providers claim against insurer for promissory estoppel was not preempted by erisa because the thirdparty provider was not bound by the terms of the erisa plan (C) recognizing fundamental distinction between firstparty and thirdparty situations and imposing fiduciary duty upon insurer to protect its insureds interest in thirdparty situations (D) recognizing common law cause of action as thirdparty beneficiary (E) holding that a plaintiff who had asserted no claim against a thirdparty defendant lacked standing to complain of the courts action with regard to the thirdparty defendant
Example Output:
holding that the governments cooperation with a thirdparty is not sufficient to establish a thirdparty beneficiary relationship