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: in a 3-2 decision does not settle the intent issue, because Honkanen did not consider the difference between intent to injure or inflict pain and intent to correct. Additionally, Honkanen’s rationale may be outdated in light of the 2001 amendments to NRS 48.061, which expand the use of bad-act evidence in domestic violence cases, 2001 Nev. Stat., ch. 360, § 1, at 169; see NRS 33.018(1)(a) (defining “domestic violence” to include battery on an accused’s minor child), and Bigpond, which recognizes that character evidence can be admissible so long as it has a credible, non- propensity purpose, such as explaining the relationship dynamics between a domestic-violence victim and the accused. 128 Nev. at 111, 270 P.3d at 1246; see also Harris v. State, 195 P.3d 161, 182 (Alaska Ct. App. 2008) (<HOLDING>). Cherry, J., concurring in part and dissenting 
 Holding statements: (A) holding that admission of rule 404b evidence was proper (B) holding that a new trial was the remedy for erroneous admission of rule 404b evidence (C) recognizing that the holding in harvey v state 604 p2d 586 590 alaska 1979 a case similar to honkanen had been abrogated by the amendment of alaskas rule 404b to allow admission of prior incidents of domestic violence as an exception to the general rule against admitting such evidence (D) recognizing general rule (E) recognizing this as the general rule
Example Output: holding that admission of rule 404b evidence was proper

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: (citing Shepard, 544 U.S. at 26, 125 S.Ct. 1254). The court then compares the elements of the crime of conviction with those of the generic offense. Descamps, 133 S.Ct. at 2281. During oral argument, the question was raised as to whether W. Va. Code § 61 — 3— 11(a) is divisible because it states alternative locational elements. See W. Va. Code § 61 — 3— 11(a) (criminalizing entry into a "dwelling house, or an outhouse” (emphasis added)). Neither party briefed this issue, and the district court did not address it below. Moreover, there are no Shepard documents in the record pertinent to Defendant’s West Virginia burglary convictions. We therefore need not and do not reach the question of divisibility to resolve this appeal. See United States v. McLeod, 808 F.3d 972, 977 (4th Cir. 2015) (<HOLDING>). Nor do we express any view as to whether W. 
 Holding statements: (A) holding that application of the modified categorical approach did not establish a covered conviction where the judgment of conviction did not contain the factual basis for the crime (B) holding that virginia burglary statute comes within definition of generic burglary (C) holding that a conviction under a divisible statute could not qualify as acca burglary pursuant to the modified categorical approach when there were no shepard documents to show that the crime of conviction was generic burglary (D) holding modified categorical approach unavailable where the statute of conviction was missing an element of the generic definition (E) holding that iowa burglary is not categorical burglary as the elements of iowa burglary law are broader than those of generic burglary
Example Output:
holding that application of the modified categorical approach did not establish a covered conviction where the judgment of conviction did not contain the factual basis for the crime