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: (9th Cir.1954) (concluding that expert opinions did not support jury verdict, in part because "[o]pinion evidence is only as good as the facts upon which it is based” and record did not support opinions). Here, for the reasons stated, the record demonstrates that the officers' percep tion of an immediate threat — whether correct or not — was clearly reasonable and therefore that their initial use of deadly force was justified. 9 . The situation Appellants faced here — having to determine in a split-second whether a suspect is using his vehicle as a weapon — is analogous to the scenario of an officer forced to make a split-second decision as to whether to use deadly force against a suspect who he believes has a firearm. See, e.g., McLenagan v. Karnes, 27 F.3d 1002, 1007 (4th Cir. 1994) (<HOLDING>); Slattery v. Rizzo, 939 F.2d 213, 215-17 (4th 
 Holding statements: (A) holding that use of deadly force was justified when suspect in vehicle repeatedly refused orders to raise his hands and the officer perceived that he was holding something (B) holding officer may search vehicle for weapons if officer has reasonable belief based on articulable facts that officer or another may be in danger (C) holding that an officer may use deadly force when a fleeing suspect threatens the officer with a weapon (D) holding that use of deadly force was justified against a suspect when officer forced to make a splitsecond decision relied on his reasonable belief that another officer had seen a gun in the suspects hands even though the suspects hands were handcuffed in front of him and the defendant officer never saw a weapon (E) holding that suspect was not in custody when officer handcuffed him for officer safety while transporting him to police station
Example Output: holding that use of deadly force was justified when suspect in vehicle repeatedly refused orders to raise his hands and the officer perceived that he was holding something

Example Input: 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
Example Output: holding that arguments raised for the first time in a reply brief are forfeited

Example Input: contractual obligation where ordinance provided for payment of health premiums, stating that “Plaintiffs’ interpretation of the 1966 ordinance would impose future liability upon the City by requiring subsequent councils to annually appropriate the fun 2d 1160, 1161 (Ind.Ct.App.1981) (discontinuation of college incentive pay program upheld even though employees allegedly worked in reliance on the program); Beckham v. City of Bowling Green, 743 S.W.2d 858, 860 (Ky.App.1987) (disallowing police officers’ attempt to parlay probable cause statutory provisions regarding reduction of salary into prohibitions against city’s “right and duty to fix the compensation of its employees based on the resources available to it.”); Watkins v. Josephine County, 243 Or.App. 52, 259 P.3d 79, 85-86 (2011) (<HOLDING>): Alston v. City of Camden, 322 S.C. 38, 471 
 Holding statements: (A) holding that where the murder and robbery occurred in one county but the plan was hatched in another county and the body was subsequently returned to that other county both counties had jurisdiction to try the appellant (B) holding that the grant county prosecutor had a statutory duty to be legal advisor to the county clerk even though she was not embroiled in litigation in which the county was the real party in interest (C) recognizing county officers as  those whose general authority and jurisdiction are confined within the limits of the county in which they are appointed who are appointed in and for a particular county and whose duties apply only to that county and through whom the county performs its usual political functions  (D) holding that no contractual obligation was created and county was not required to refrain from amending personnel benefits resolution stating that county never promised the permanence of the disputed benefits  (E) holding that both saline county and grant county had jurisdiction to try the appellant for murder where the actual killing occurred in one county but the acts requisite to the consummation of the murder and the subsequent disposal of the body occurred in the other county
Example Output:
holding that where the murder and robbery occurred in one county but the plan was hatched in another county and the body was subsequently returned to that other county both counties had jurisdiction to try the appellant