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]: § 924(c) conviction is invalid after Bailey and Bousley, it argues we are prohibited from reaching the merits of his claim because Abdullah did not present his Bailey/Bousley challenge on direct appeal or in the § 2255 proceedings below. Alternatively, the government argues the claim is barred by AEDPA’s one-year limitations period. We assume for purposes of this appeal that Abdullah did not procedurally default his Bailey claim by failing to raise it on direct appeal. Notwithstanding such an assumption, we conclude the claim is barred because Abdullah failed to adequately raise the issue before the district court in this § 2255 proceeding. Generally, a habeas claim cannot be raised by a petitioner for the first time on appeal. See, e.g., Petty v. Card, 195 F.3d 399, 400 (8th Cir.1999) (<HOLDING>), cert. denied, — U.S. -, 121 S.Ct. 78, 148 
 Holding statements: (A) holding that issues not raised before the district court cannot be raised for the first time before this court (B) holding that the convention claim was procedurally defaulted (C) holding that court may address procedurally defaulted claim on the merits where it is more efficient to do so (D) holding that habeas claim not included in petition and never raised by petitioner before the district court as basis for habeas relief is procedurally defaulted (E) holding that an argument not raised before the district court is procedurally defaulted
[EX A]: holding that issues not raised before the district court cannot be raised for the first time before this court

[EX Q]: this is irrelevant to the question of whether a loan was made to Busson-Sokolik in the first place. Finding no clear error on the question of whether the funds were in fact transferred to Busson-Sokolik and no defects in the formation of a valid contract between the parties, we affirm the finding that the sum MSOE transferred to Busson-Sokolik was a loan. 2 . “Abuse of discretion” is the clear standard for evaluating a judge’s decision to impose sanctions in a bankruptcy case. See In re Rimsat, Ltd., 212 F.3d 1039, 1046 (7th Cir.2000). While the standard for evaluating a judge’s decision not to impose sanctions in a bankruptcy case is somewhat less clear, we adopt the Sixth Circuit’s approach of using the "abuse of discretion” standard. See In re Downs, 103 F.3d 472, 480 (6th Cir.1996) (<HOLDING>). 3 . An appeal is frivolous "when the result 
 Holding statements: (A) holding that the appropriate standard of review is abuse of discretion (B) holding that the applicable standard of review for evaluating a bankruptcy courts denial of fed r bankrp 9011 sanctions is abuse of discretion and noting similar approaches taken by the ninth and tenth circuits (C) holding that the standard of review for the denial of rule 11 sanctions is governed by the law of the regional circuit (D) holding that the conclusion that the wiretap was necessary in each situation is reviewed for an abuse of discretion and bringing the tenth circuit into accordance with the authority of a majority of other circuits (E) holding that the standard of review is abuse of discretion and an appeal from denial of rule 60b relief does not bring up the underlying judgment for review
[EX A]: holding that the appropriate standard of review is abuse of discretion

[EX Q]: Cir.2005). The undisputed evidence in this case reveals that neither Arbaney, Lakey, nor Couch was similarly situated to Ramon. Ramon was younger and not as close to being eligible for retirement as were Arbaney and Lakey, and there is no evidence that Continental uncovered any wrongdoing by Couch. These differences between Ramon’s situation and that of her comparators justified the differential treatment, and Ramon cannot demonstrate that she was “similarly situated” to them. See Wyvill v. United Cos. Life Ins.. Co., 212 F.3d 296, 305 (5th Cir.2000) (affirming summary judgment where “the striking differences between the two men’s situations more than account for the different treatment they received”); see also Nelson v. Gen. Elec. Co., 2 Fed. Appx. 425 (6th Cir.2001) (unpublished) (<HOLDING>); Thomas v. Hilts, No. 224690, 2002 WL 234757, 
 Holding statements: (A) holding that plaintiff was not similarly situated to another employee who also engaged in protected activity for purposes of plaintiffs retaliation claim (B) holding that a similarly situated employee is one who is comparable to plaintiff in all material respects (C) holding that employee who violated a different policy of the store than plaintiff was not similarly situated (D) holding that potential class members are similarly situated to the named plaintiffs if they are similarly situated with respect to their job requirements and pay provisions (E) holding that younger employee not similarly situated to older employee who committed similar infraction and was allowed to remain on job for a few extra months and obtain retirement eligibility
[EX A]:
holding that plaintiff was not similarly situated to another employee who also engaged in protected activity for purposes of plaintiffs retaliation claim