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.

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
holding that individual employees are not liable under title vii

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
holding that arguments raised for the first time in a reply brief are forfeited

look first to the bottom line to see whether the overall fee is reasonable. If it is, they pay the bill. If it is not, they challenge enough of the hours so that the result will produce a reasonable fee. 6 .See Florida v. Rodriquez, 469 U.S. 1, 5-6, 105 S.Ct. 308, 310-11, 83 L.Ed.2d 165 (1984) (finding that articulable suspicion, rather than probable cause, was sufficient for seizure of defendants in a major international airport, and noting that extensive anti-hijacking surveillance and equipment created a lesser reasonable expectation of privacy (citing Florida v. Royer, 460 U.S. 491, 515, 103 S.Ct. 1319, 1333, 75 L.Ed.2d 229 (1983) (Blackmun, J., dissenting))); United States v. Moreno, 475 F.2d 44, 47-49 (5th Cir.), cert. denied, 414 U.S. 840, 94 S.Ct. 94, 38 L.Ed.2d 76 (1973) (<HOLDING>). 7 . Counsel's suggestion to the jury that it 
 Holding statements: (A) holding that warrantless arrest based on probable cause did not violate the fourth amendment (B) holding that fourth amendment applicable in administrative searches for safety inspections (C) holding that the threat of air piracy justifies special fourth amendment considerations in airports akin to those at border crossings which allow warrantless searches in certain cases (D) holding that such interactions in airports are the sort of consensual encounters that implicate no fourth amendment interest (E) holding that under the fourth amendment a party may challenge both the constitutionality of the act permitting warrantless searches as well as the conduct of the government officials in a particular case

holding that warrantless arrest based on probable cause did not violate the fourth amendment