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]: for relief under § 3582(c). Nor is Brown entitled to pursue his claims through § 2241. A prisoner may proceed under § 2241 if § 2255 would be “inadequate of ineffective.” 28 U.S.C. § 2255(e); Cradle v. United States ex rel. Miner, 290 F.3d 536, 538 (3d Cir.2002) (per curiam). We have held that § 2255’s “safety valve” applies only in rare circumstances, such as when an intervening change in the statute under which the petitioner was convicted renders the petitioner’s conduct non-criminal. See In re Dorsainvil, 119 F.3d 245, 251 (3d Cir. 1997). Brown has not satisfied that standard here, as he makes no allegation that he is actually innocent of the crime for which he was convicted, but instead asserts only that he is “innocent” of being a career offender. See Okereke, 307 F.3d at 120-21 (<HOLDING>). Brown must obtain a certificate of 
 Holding statements: (A) holding that prisoners challenge to his sentencing enhancement under  841 and 846 was not cognizable under  2241 (B) holding that a change in the law of sentencing does not constitute a new factor (C) holding that a  2241 petitioners claim was not cognizable under  2241 and therefore the district court lacked jurisdiction (D) holding that dorsainvil did not permit petitioner to challenge sentence via  2241 based on intervening change in sentencing law (E) holding challenge to armedcareercriminal enhancement improper under  2241
[EX A]: holding that prisoners challenge to his sentencing enhancement under  841 and 846 was not cognizable under  2241

[EX Q]: venture” (FAC ¶ 39) are similarly insufficient. See Cannon v. Douglas Elliman, L.L.C., No. 06-CV-7092, 2007 WL 4358456, at *4 n. 3 (S.D.N.Y. Dec. 10, 2007) (“[Pjleading a joint venture does not trigger joint employer status because it is possible for joint ventures to separately employ different people .... ”); Hibbs-Rines v. Seagate Techs., L.L.C., No. 08-CV-5430, 2009 WL 513496, at *5 (N.D.Cal. Mar. 2, 2009) (“Plaintiff joint employer allegations are insufficient because they are legal conclusions, not factual allegations, .... While plaintiff is not required to conclusively establish that defendants were her joint employers at the pleading stage, plaintiff must at least allege some facts in support of this legal conclusion.”) cf. Patel v. Wargo, 803 F.2d 632, 635-36 (11th Cir.1986) (<HOLDING>). Plaintiffs arguments that these Defendants 
 Holding statements: (A) holding under flsa 29 usc  216c (B) holding that the authorization under 29 usc  1132a3 extends to a suit against a nonfiduciary party in interest to a transaction barred by 29 usc  1106a (C) holding under 29 usc  216c (D) holding that the finding that entities constitute a single enterprise under 29 usc  203r is separate and distinct from whether an entity is an employer under 29 usc  203d (E) holding that the defendant is in the best position to prove and should bear the burden of establishing its entitlement to an exemption under 29 usc  1108 from 29 usc  1106b erisas prohibited transactions provision
[EX A]: holding under flsa 29 usc  216c

[EX Q]: decision contained numerous citations to both federal precedent and state court decisions which were based on federal due process principles. In the FAR petition, Davis specifically noted the factual underpinnings of his claim: “[T]he prosecutors suppressed the fact that Frame ... refused to be interviewed by the defendants because of threats by Delinsky....” Pet’r’s Mem.Ex. A at 24. Davis focused his argument in the FAR petition, however, on the failure of the trial justice to hold an evidentiary hearing regarding this and other suppression claims. See id. at 25. Davis characterized his claims as “allegations of constitutional violations,” “allegations of constitutional dimensions,” and as a “Due Process” violation contrary to United States v. Dansker, 565 F.2d 1262 (3d Cir.1977) (<HOLDING>), cert. dismissed, 434 U.S. 1052, 98 S.Ct. 905, 
 Holding statements: (A) holding that there was a genuine issue of material fact precluding summary judgment (B) holding nonmoving partys affidavit created genuine issue of material fact as to the existence of an employment relationship (C) holding that plaintiff failed to show genuine issue of material fact on equitable estoppel claim (D) holding that where affidavits raise a genuine issue of material fact as to a brady claim an evidentiary hearing should be conducted (E) holding that due process requires an evidentiary hearing when parties submissions in contempt proceedings raise disputed issue of material fact
[EX A]:
holding that there was a genuine issue of material fact precluding summary judgment