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.

Q: rise to the level of the allegations in Harke-ma. While physical abuse obviously endangers a child, Ma Donna’s account of her January 1997 fight with F.G. is not inconsistent with F.G.’s charge (except for the allegation of hair-pulling). An alleged single incident of borderline abuse or neglect has been held not to constitute sufficient endangerment to warrant a custody modification. See Smith, 508 N.W.2d at 227 (insufficient endangerment where child was injured by fallen cuckoo clock and mother allegedly examined clock before child). Under the circumstances, the court did not abuse its discretion in giving this incident little weight. This court has been inconsistent in categorizing a custodial parent’s efforts to isolate the child from relatives. Compare Westphal, 457 N.W.2d at 229 (<HOLDING>) with Smith, 508 N.W.2d at 227 (stating that a 
 Holding statements: (A) holding that postadoption visitation of child who was adopted by grandparents on basis of biological parents unconditional consent was required to promote childs best interests (B) holding that paramount consideration in terminationofparentalrights proceeding is best interests of the child (C) holding mothers cutting off contact with grandparents to be best interests consideration but not evidence of endangerment (D) holding that best interests of the child analysis requires consideration of all section 5328a factors (E) holding unconstitutional a statute authorizing courts to recognize grandparents as having the same standing as parents for evaluating what custody arrangements are in the best interest of the child where the child actually resided with the grandparents in a stable relationship

A: holding that postadoption visitation of child who was adopted by grandparents on basis of biological parents unconditional consent was required to promote childs best interests
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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

A: holding that arguments raised for the first time in a reply brief are forfeited
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Q: district court’s decision of whéther to give a jury instruction and the content of the instruction. See United States v. Abbas, 74 F.3d 506, 513 (4th Cir.1996). A court’s refusal to give a requested instruction is reversible error if the instruction “(1) was correct; (2) was not substantially covered by the court’s charge to the jury; and (3) dealt with some point in the trial so important, that failure to give the requested instruction seriously impaired the defendant’s ability to conduct his defense.” United States v. Lewis, 53 F.3d 29, 32 (4th Cir.1995). We conclude the district court provided an adequate specific intent instruction to the jury, and thus was not required to give an additional instruction on good faith. See United States v. Fowler, 932 F.2d 306, 317 (4th Cir.1991) (<HOLDING>). Thus, this claim is without merit. II. 
 Holding statements: (A) holding that issue of inadequate jury instruction was waived because the instruction given was the one expressly requested by defense counsel (B) holding that in a criminal trial the trial court must correct or amend an improper instruction if the proper instruction is necessary for the jury to understand the case (C) holding that when no objection was made to jury instruction evidence to support finding based on instruction should be assessed in light of the instruction given (D) holding that a specific pretext instruction is not necessary (E) holding good faith jury instruction is not necessary when the court has given an adequate specific intent instruction

A:
holding that issue of inadequate jury instruction was waived because the instruction given was the one expressly requested by defense counsel
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