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.

The savings clause states that “[compliance with an order [under the MDA] shall not relieve any person from liability under Federal or State law.” 21 U.S.C.A. § 360h(d). While the savings clause almost certainly prohibits a holding that the MDA preempts all state law liability, our interpretation of § 360k(a) does not preclude all liability. Further, nothing in the savings clause suggests that some tort liability, as opposed to other types of liability, must be preserved. Interpreting the savings clause to preserve non-tort liability, such as contract liability, is not only permissible, but also comports with the Supreme Court’s interpretation of a savings clause in a recent preemption case. See American Airlines, Inc. v. Wolens, — U.S. -, -, 115 S.Ct. 817, 826, 130 L.Ed.2d 715 (1995) (<HOLDING>). Moreover, where the preemptive intent of 
 Holding statements: (A) holding the illinois consumer fraud act preempted by the federal airline deregulation act to the extent the state law applied to airline frequent flier programs (B) holding consumer claims under the texas deceptive trade practices act nonassignable (C) holding that the airline deregulation act preempts claims under the illinois consumer fraud and deceptive business practices act but does not preempt state breach of contract actions (D) holding that erisa preempts a plaintiffs claims for violation of the state insurance code and consumer protection act (E) holding that cjlaims for unfair competition and deceptive business practices involving trade names brought under illinois statutes are to be resolved according to the principles set forth under the lanham act and noting that illinois courts look to federal case law and apply the same analysis to state infringement claims
holding the illinois consumer fraud act preempted by the federal airline deregulation act to the extent the state law applied to airline frequent flier programs

the report and recommendation did not notify the parties that they must file timely objections to preserve their right to appellate review. He argues that the firm waiver rule should not be enforced in the absence of such an explicit notification. While we have held that the firm waiver rule is inapplicable when pro se litigants are not given explicit notice of the rule, see id. at 659, we have never extended that practice to counseled cases. We decline to do so today, because we expect counsel to know the rules. See Nasious v. Two Unknown B.I.C.E. Agents, 492 F.3d 1158, 1163 n. 5 (10th Cir.2007) (“[W]e expect counsel to know the pleading rules of the road without being given personal notice of them by the district court.”); United States v. Windrix, 405 F.3d 1146, 1157 (10th Cir.2005) (<HOLDING>). While 28 U.S.C. § 636(b)(1) provides that a 
 Holding statements: (A) holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules (B) holding that a criminal defendants counsel is charged with knowledge of the local criminal rules in their entirety including those parts of the local civil rules incorporated by reference (C) holding the district court did not abuse its discretion in applying its own local rules even though those rules prevented it from considering some facts improperly alleged by plaintiffs that might have been relevant to the summary judgment motion (D) holding that the federal expert witness compensation rules are in direct conflict with the state rules even when the state rules allow for a greater recovery (E) holding that defendants have a right to counsel in criminal proceedings
holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules

violations that the Guidelines classify as Grade C, U.S. Sentencing Guidelines Manual ("U.S.S.G.”) § 7B 1.4(a), p.s., have not received prison terms following supervised release revocations. Mr. Manning's comparatively short sentence was imposed on March 31, 2008. Mr. Manning had been detained on the supervised release revocation charge for more than two months before sentencing. At this juncture, although the clock has not run on the ten months, if Mr. Manning was given the statutorily prescribed credit for that time, see, e.g., Weekes v. Fleming, 301 F.3d 1175, 1178 (10th Cir.2002) (construing 18 U.S.C. § 3585(b)), in all likelihood he has completed his sentence. Indeed, publicly available Bureau of Prison records indicate that Mr. Manning completed his prison 883-84 (10th Cir.2008) (<HOLDING>). And, even if there were some very slight room 
 Holding statements: (A) holding that invitederror doctrine precludes defendant from challenging sentence of supervised release where defendant requested sentence of supervised release (B) holding that further supervised release may be ordered as a sentence for violation of supervised release (C) holding that reasonableness review applies to a sentence imposed upon a revocation of supervised release (D) holding that a completed term of confinement did not render a challenge to the reasonableness of a sentence moot where defendant could receive a reduced term of supervised release (E) holding substantive reasonableness sentencing challenge to be moot when defendant had completed prison sentence but addressing challenge to supervised release conditions

holding that invitederror doctrine precludes defendant from challenging sentence of supervised release where defendant requested sentence of supervised release