TASK DEFINITION: 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.
PROBLEM: are differences between sanctions under Rule 37(a) and substitution of counsel conditioned on payment of fees, the parallel considerations convince us that the Cunningham rationale applies here. Like Rule 37(a) sanctions, the present situation invokes concerns regarding finality, avoiding piecemeal appeals, and availability of effective appellate review.” Id. Cases from the First, Second, Third, and Fifth Circuits further support interpreting Cunningham as applying more broadly than to Rule 37(a) sanctions alone. The First Circuit recognized in Empresas Omajede, Inc. v. Bennazar-Zequeira, 213 F.3d 6, 9 n. 4 (1st Cir.2000), that Cunningham affirmed its precedents denying interlocutory appeals in the sanctions area. See, e.g., United States v. Kouri-Perez, 187 F.3d 1, 14 (1st Cir.1999) (<HOLDING>); Appeal of Licht & Semonoff 796 F.2d 564, 573 
 Holding statements: (A) holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable (B) holding sanctions pursuant to rule 26g not immediately appealable (C) holding sanctions order pursuant to district courts inherent powers not immediately appealable (D) holding such denial to be an immediately appealable collateral final order (E) holding an order of rule 37a sanctions against an attorney is immediately appealable under  1291

SOLUTION: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

PROBLEM: of the debtor. This distinction appears immaterial under the language of sec. 409.402(7), Stats. 7 In other contexts, a security interest properly perfected at one time may later become unperfected through creditor inaction. See, e.g. sec. 409.103(l)(d)l, (2)(b), (3)(e), Stats, (four month grace periods preserving perfection in collateral removed from jurisdic tion); sec. 409.403(2) (lapse of financing statements after 5 years unless continued). 8 Interestingly, the Ansley court held that a filing under "the name Ansley Farms instead of the debtor's true name — Emory Ansley — is seriously misleading, making [the]. . . security interest unperfected.. . ." Id,., 467 F.Supp. at 55. Other cases reaching similar results are In Re Wishart, 10 U.C.C. Rep. Serv. 1296 (Bankr.W.D. Mich. 1972) (<HOLDING>); In Re Brawn, 7 U.C.C. Rep. Serv. 565 (D.C. 
 Holding statements: (A) holding that the filing of notice without motion is insufficient (B) holding a filing under mccauleys reprographics and mapping insufficient to perfect a security interest in the assets of the debtor corporation (C) holding that the reservation of a claim need not name a defendant but only identify the type of claim the debtor seeks to retain (D) holding a filing under wishart equipment co insufficient to identify the debtor horace wishart (E) holding a filing under john and mayella lintz insufficient to identify the debtor corporation

SOLUTION: holding that the filing of notice without motion is insufficient

PROBLEM: the trial judge had seen the videotape of James Eas-ley impheating Woodard, the trial court’s conclusion, without explanation or a hearing, that there was no “deceit or trickery” appears unsupported by the bare record before us. Whether the government indeed threatened Woodard with a murder charge if he did not testify before the grand jury, or diverted him from consulting with his attorney before he did so, or misled him into thinking he was not a target, are open questions of fact that must be tested at a hearing. Whether all or some of those alleged facts, even if true, undercut the voluntariness of his grand jury testimony despite the Miranda waiver, is a question that only a hearing can begin to answer. See Miller v. Fenton, 474 U.S. 104, 115, 106 S.Ct. 445, 88 L.Ed.2d 405 (1985) (<HOLDING>)”. I’m sure that the government will object to 
 Holding statements: (A) holding that under 28 usc  2254d the ultimate question of the admissibility of a confession merits treatment as a legal inquiry requiring plenary  review (B) recognizing the possibility that 28 usc  1331 supplies jurisdiction for violations of international law but not reaching the ultimate merits of the issue (C) holding that the ninth circuits decision exceeded the limits imposed on federal habeas review by 28 usc  2254d (D) holding that a claim brought in a pro se brief that the state court did not address was not adjudicated on the merits as required by  2254d (E) recognizing that the ultimate question of the voluntariness of consent is one of law

SOLUTION:
recognizing the possibility that 28 usc  1331 supplies jurisdiction for violations of international law but not reaching the ultimate merits of the issue