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.

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

the Department must make in order to obtain the order it seeks in this action, as well as certain other issues that are likely to arise on remand. We conclude the Department's petition adequately sets forth the necessary elements it must prove in order to involuntarily treat Saenz: (1) that he has refused to consume food and fluids sufficient to maintain his health for an extended period; (2) that, as a result, he has been diagnosed by a physician as suffering from moderate to severe malnutrition, dehydration or other deleterious condition; and (3) that, pursuant to reliable medical opinion, Saenz is in imminent danger of suffering serious harm or death unless he is given medical treatment, including, if necessary, forced hydration and/or forced feeding. Cf. Harper, 494 U.S. at 227 (<HOLDING>). ¶ 29. We next consider the Department's 
 Holding statements: (A) holding that the due process clause permits the state to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will if the inmate is dangerous to himself or others and the treatment is in the inmates medical interest (B) holding that an inmate stated a claim under the due process clause when guards had placed her in a cell with a dangerous inmate (C) holding that a detention officers alleged negligent conduct of failing to medically screen an inmate who later committed suicide in a holding cell  in violation of the police departments policies  was not the proximate cause of the inmates death when there was no evidence that the inmate would have been unable to kill himself if he had been medically screened and any claim that the inmate would have presented as suicidal in such screening was purely speculative (D) holding that the due process clause permits the state to involuntarily treat a prison inmate who is seriously mentally ill if the inmate is dangerous to himself or others and the treatment is in the inmates medical interest (E) holding that the due process clause permits the state to treat a prison inmate  with antipsychotic drugs against his will under certain circumstances while not limiting treatment to those circumstances
holding that the due process clause permits the state to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will if the inmate is dangerous to himself or others and the treatment is in the inmates medical interest

Id, at 353, 332 S.E.2d at 808. The Court in Atkinson refused to expand the “bom alive” rule to cover criminal offenses, holding, “Neither our murder statute, W.Va. Code, 61-2-1, nor its attendant common law principles authorize prosecution of an individual for the killing of a viable unborn child.” Id., Syllabus Point 2. Since Atkinson was decided, the Legislature passed the Unborn Victims of Violence Act, which provides that a “fetus” can be the victim of certain violent ding a mother was not criminally liable for knowingly causing injury to a child under circumstances likely to produce death or serious physical injury after the mother’s pre-birth ingestion of heroin caused her child to suffer heroin withdrawal symptoms postpartum); Collins v. State, 890 S.W.2d 893 (Tex.Ct.App.1994) (<HOLDING>); Sheriff, Washoe Cnty. v. Encoe, 110 Nev. 
 Holding statements: (A) holding that a woman possessed immunity from criminal prosecution for causing injury or death to her fetus (B) holding an unborn child is not a child for purposes of criminal prosecution of mistreatment of a child (C) holding for purposes of establishing the offense of reckless manslaughter against a pregnant woman a fetus is not a person (D) holding a mothers ingestion of a controlled substance while pregnant does not constitute child abuse as an unborn child is not a person for purposes of criminal prosecution (E) holding a fetus is not a child person or individual for purposes of criminal prosecution under the reckless injury to a child statute

holding that a woman possessed immunity from criminal prosecution for causing injury or death to her fetus