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]: plenary determination of jurisdiction over five landlocked canals); Weiszmann v. District Engineers, U.S. Army Corp, 526 F.2d 1302 (5th Cir.1976) (same outcome as in Sexton Cove in action brought by landowner); U.S. v. St. Bernard Parish, 589 F.Supp. 617 (E.D.La.1984) (plenary trial determining jurisdictional issue); U.S. v. Lambert 589 F.Supp. 366 (M.D.Fla.1984) (plenary trial determining property was a wetland; proof by preponderance of evidence was measure of government’s burden of persuasion); U.S. v. Ciampitti, 583 F.Supp. 483 (D.N.J.1984) (in action for preliminary injunction, court made own determination that property was a wetland); U.S. v. City of Fort Pierre, 580 F.Supp. 1036 (D.S.D.1983) (plenary trial determining property was a wetland) rev'd, 747 F.2d 464 (9th Cir.1984) (<HOLDING>); Parkview Corp. v. Department of Army Corp of 
 Holding statements: (A) holding that plaintiffs may have a property interest in real property (B) holding property not a wetland (C) holding that the debtor could retain exempt property because it was not property of the estate (D) recognizing that exempt property ceases to be property of the estate (E) holding that because property was no longer property of the estate the court could not order turnover
[EX A]: holding that plaintiffs may have a property interest in real property

[EX Q]: 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
[EX A]: holding that arguments raised for the first time in a reply brief are forfeited

[EX Q]: of no more than ten pages and limited to the private search issue, by November 3, and the government is ordered to submit a supplemental sur-reply, also of no more than ten pages and limited to the private search issue, by November 10. A suppression hearing is scheduled for November 13 at 10 AM. SO ORDERED. 1 . The exact meaning of "Internet Service Provider” is unclear. Wikipedia defines the term broadly — to encompass not only entities that provide "internet service,” thereby allowing consumers to get online (such as Comcast and Tim 014 WL 2918271, at *2 (N.D.Cal. June 26, 2014). 67 . See United States v. Caraballo, 963 F.Supp.2d 341, 361 (D.Vt.2013). But see In re United States for an Order Authorizing the Release of Historical Cell-Site Infonnation, 809 F.Supp.2d 113 (E.D.N.Y.2011) (<HOLDING>). 68 . With respect to one of the electronic 
 Holding statements: (A) holding that cumulative cellsite  location records require a warrant because of the significant governmental intrusion into information which is objectively recognized as highly private  that is the governments surveillance of ones movements over a considerable time period (B) holding inmates have some fourth amendment protection where no institutional need is served by the search (C) holding that records relating to a student court were not education records (D) holding that fourth amendment protection extends to cellsite location records (E) recognizing an implied fourth amendment action for damages
[EX A]:
holding that cumulative cellsite  location records require a warrant because of the significant governmental intrusion into information which is objectively recognized as highly private  that is the governments surveillance of ones movements over a considerable time period