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]: a factor listed in this subpart, departure from the applicable guideline range is warranted only if the factor is present to a degree substantially in excess of that which ordinarily is involved in the offense. U.S.S.G. § 5K2.0, p.s. Indeed, we have recognized the possibility of departure beyond the adjustments made available by U.S.S.G. §§ 3B1.1 (aggravating role) and 3B1.2 (mitigating role), based upon a defendant’s extraordinary role with respect to the offense of conviction. See United States v. Joyner, 924 F.2d 454, 461 (2d Cir.1991) (acknowledging possibility of role “so extraordinarily minute that [defendants] deserved a departure beyond the four-level maximum reduction available for ‘minimal’ participation”); United States v. Colon, 905 F.2d 580, 585-86 (2d Cir.1990) (<HOLDING>); cf. United States v. Bierley, 922 F.2d 1061, 
 Holding statements: (A) recognizing that where there are other persons who are criminally responsible for the offense who have not been apprehended or have not been charged due to cooperation a sole defendant may be eligible for an upward or downward adjustment for role in the offense (B) holding that within these parameters apprendi permits an upward adjustment for a defendants role in a drugtrafficking conspiracy (C) recognizing potential upward adjustment beyond that provided by guidelines for aggravating role in the offense (D) holding that role in the offense is a factual determination albeit complex a district courts decision not to apply an adjustment based on such a determination is reversed only for clear error (E) holding that a defendant convicted of a soleparticipant offense may nonetheless be entitled to a mitigating role adjustment
[EX A]: recognizing that where there are other persons who are criminally responsible for the offense who have not been apprehended or have not been charged due to cooperation a sole defendant may be eligible for an upward or downward adjustment for role in the offense

[EX Q]: re Haddad), 68 B.R. 944, 948 (Bankr.D.Mass.1987); Williams v. Clark (In re Clark), 91 B.R. 324, 332-34 (Bankr.E.D.Pa.1988). And, although § 105 “does not authorize the bankruptcy courts to create substantive rights that are otherwise unavailable under applicable law,” Pertuso, 233 F.3d at 423, n. 1; “[b]ankruptcy courts ... enjoy inherent power to sanction parties for improper conduct.” Mapother & Mapother v. Cooper (In re Downs), 103 F.3d 472, 477 (6th Cir.1996). This inherent power authorizes federal courts “to protect their proceedings and judgments in the course of discharging their traditional responsibilities.” Degen v. United States, 517 U.S. 820, 823, 116 S.Ct. 1777, 135 L.Ed.2d 102 (1996). See also Chambers v. NASCO, Inc., 501 U.S. 32, 50, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991)(<HOLDING>); Jones v. Bank of Santa Fe (In re Courtesy 
 Holding statements: (A) recognizing that court has inherent power to control the judicial business before it (B) recognizing inherent power of courts of appeals (C) recognizing district courts inherent authority to dismiss with prejudice for abuse of judicial process (D) recognizing inherent power of federal district court to sanction conduct abusive of judicial process (E) recognizing courts inherent power to impose sanctions including attorneys fees for conduct that abuses the judicial process
[EX A]: recognizing that court has inherent power to control the judicial business before it

[EX Q]: no greater than is essential to the furtherance of that interest. Id. at 377, 88 S.Ct. 1673. We assume, without deciding, that the Sexual Solicitation Statute may place some incidental limitations on First Amendment freedoms, but we conclude that each of the O’Brien factors is met in this case. Thus, any incidental limitation on expression protected by the First Amendment is justified. We will address each factor in turn. First, it is within the power of the state to enact the Sexual Solicitation Statute. “The traditional police power of the States is defined as the authority to provide for the public health, safety, and morals, and [the U.S. Supreme Court has] upheld such a basis for legislation.” Barnes v. Glen Theatre, Inc., 501 U.S. 560, 569, 111 S.Ct. 2456, 115 L.Ed.2d 504 (1991) (<HOLDING>); see, e.g., Arcara, 478 U.S. at 711, 106 S.Ct. 
 Holding statements: (A) holding that significant involvement of government agency charged with protecting public environmental interest satisfies public participation requirement in certain circumstances (B) holding that a public indecency statute furthers a substantial government interest in protecting order and morality (C) recognizing michigans rape shield law furthers the legitimate state interests of protecting a sexual assault victim from surprise harassment and unnecessary invasions of privacy (D) holding that governments asserted interest in protecting the privacy of arrestees is substantial under central hudson (E) recognizing minnesotas interest in protecting the interests of the child
[EX A]:
holding that significant involvement of government agency charged with protecting public environmental interest satisfies public participation requirement in certain circumstances