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: Mickey v. Zeidler Tool & Die Co., 516 F.3d 516, 523-26 (6th Cir.2008). Here, the Plaintiff was terminated by the Defendants three weeks after the filing of the Complaint in this case. This close temporal proximity between the Plaintiffs protected activity and the adverse employment action is sufficient evidence such that a reasonable juror could conclude that the adverse employment action would not have occurred but for his engagement in pro tected activity. See Dixon v. Gonzales, 481 F.3d 324, 334 (6th Cir.2007) (“This Court typically [has] found the causal connection element [is] satisfied only where the adverse employment action occurred within a matter of months, or less, of the protected activity”); see also Herrera v. Churchill McGee, LLC, 545 Fed.Appx. 499, 501 (6th Cir.2013) (<HOLDING>); Shefferly v. Health Alliance Plan of Mich., 
 Holding statements: (A) holding that a temporal proximity of one month between the plaintiffs protected activity and adverse employment action was sufficient to establish a causal connection (B) holding in a discrimination case that a close temporal proximity sufficient to survive summary judgment existed where the challenged employment action occurred one month after the protected activity (C) holding that intervening misconduct can sever the temporal proximity connection between the protected conduct and the adverse employment (D) holding that temporal proximity between the alleged retaliators knowledge of a protected activity and an adverse employment action may be sufficient to establish causal connection or retaliatory motive in some cases (E) holding that five weeks between protected activity and adverse employment action insufficient to establish a causal connection
Example Output: holding in a discrimination case that a close temporal proximity sufficient to survive summary judgment existed where the challenged employment action occurred one month after the protected activity

Example Input: misconduct “that has affected the grand jury’s charging decision and is brought to the attention of the trial court before the commencement of trial”). The defendant suggests that Benjamin should not be applied retroactively to bar her claim. See Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07, 92 S.Ct. 349, 355, 30 L.Ed.2d 296 (1971) (setting forth a three-part test for determining whether a judicial decision should be applied retroactively). We sympathize with the defendant’s belief that retroactive application of Benjamin to preclude any appeal would “pro duce substantial inequitable results.” Id. at 107, 92 S.Ct. at 355 (quoting Cipriano v. City of Houma, 395 U.S. 701, 706, 89 S.Ct. 1897, 1900, 23 L.Ed.2d 647 (1968)); cf. Gibson v. United States, 781 F.2d 1334, 1339-40 (9th Cir.1986) (<HOLDING>), cert. denied, _ U.S. _, 107 S.Ct. 928, 93 
 Holding statements: (A) holding that a shortened statute of limitations should not be applied retroactively as to bar otherwise valid civil claims (B) holding that annulment of the automatic stay can be retroactively applied to validate proceedings that otherwise would be void (C) holding amendment to statute of limitations was a procedural amendment to be applied retroactively in a medical malpractice case (D) holding statute that extended statute of limitations for certain criminal sexual conduct could not be applied retroactively to a prosecution commenced after the limitations statute in effect at the time of the alleged offense had expired (E) holding generally that new rules of law should not be applied retroactively in habeas corpus cases
Example Output: holding that annulment of the automatic stay can be retroactively applied to validate proceedings that otherwise would be void

Example Input: this instruction. However, the court later stated that it had allowed the aforementioned questionin ounsel argued in his closing argument the very point which he contends he was denied the opportunity to make — that Elliott’s willingness to take a lie detector test demonstrated a lack of consciousness of guilt. The Commonwealth argues that the PCRA court’s denial of relief on this ineffectiveness claim is correct because the underlying claim of trial court error is meritless. First, it argues that this Court has already ruled that testimony regarding a defendant’s purported willingness to undergo a polygraph examination is inadmissible for the same reasons that a defendant’s refusal to take such test is inadmissible. Commonwealth v. Saun ders, 386 Pa. 149, 125 A.2d 442, 445-46 (1956) (<HOLDING>). The Commonwealth further submits that 
 Holding statements: (A) holding that when counsel denied the petitioner the right to appeal neither the strickland prejudice prong nor the harmlesserror test is appropriate (B) holding that it is not (C) holding that expert testimony should not be admitted as to a matter that is obviously within the common knowledge of jurors because such testimony almost by definition can be of no assistance (D) holding that an error is plain if it is clear or obvious (E) holding that because a polygraph test is not judicially acceptable it is obvious that neither a professed willingness nor a refusal to submit to such a test should be admitted because a defendants willingness is merely a selfserving act or declaration which obviously could be made without any possible risk
Example Output:
holding that when counsel denied the petitioner the right to appeal neither the strickland prejudice prong nor the harmlesserror test is appropriate