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]: of benefits in 1989 established a "pattern” of benefit increases such that the Plan's later rescission of the 1999 Benefits Increase, which was adopted ten years after the 1989 increase, violated the anti-cutback rule. We find this argument to be without merit as a matter of law. 18 . Thornton also alleges that the Board breached its fiduciary duty by favoring one class of Plan participants over another class, specifically by eliminating the 1999 Benefits Increase for pre-February 1, 1999 retirees while maintaining it for Plan participants retiring on or after that date. Thornton waived this argument on appeal, however, by waiting until his reply brief to address the issue, rather than raising it first in his opening brief. United States v. Perkins, 994 F.2d 1184, 1191 (6th Cir.1993) (<HOLDING>). 19 . 29 U.S.C. § 1132(a) states in relevant 
 Holding statements: (A) holding that arguments raised for the first time in a reply brief are forfeited (B) holding that an argument raised for the first time in a reply brief is waived (C) holding that issue raised for the first time in reply brief was waived (D) holding issues raised for the first time in a reply brief are not properly before this court (E) holding that issues not raised before the district court cannot be raised for the first time before this court
[EX A]: holding that arguments raised for the first time in a reply brief are forfeited

[EX Q]: N.E.2d 968, 973 (Ind.1999). However, when the landowner is a lessor and the lessee is in operational control of the premises, such duty rarely exists. “[A] landlord under many circumstances has no liability to tenants or others for injuries on the property when the tenant is in full control of the leased premises.” Dutchmen Mfg., Inc. v. Reynolds, 849 N.E.2d 516, 525 (Ind.2006). “[I]n the absence of statute, covenant, fraud or concealment, a landlord who gives a tenant full control and possession of the leased property will not be liable for personal injuries sustained by the tenant or other persons lawfully' upon the leased property.” Olds v. Noel, 857 N.E.2d 1041, 1044 (Ind.Ct.App.2006) (citation omitted), tram, not' sought; cf. Rossow v. Jones, 404 N.E.2d 12, 14 (Ind.Ct.App.1980) (<HOLDING>), trans. not sought. Yost v. Wabash College, 3 
 Holding statements: (A) holding over (B) holding that captain has reasonable expectation of privacy in all areas of his ship (C) holding that defendants had no reasonable expectation of privacy in the common areas of an apartment building (D) holding that a landlord has a duty of reasonable care over common areas or other areas over which the landlord has retained control (E) holding that a landlord may have a duty to exercise reasonable care for the safety of its tenants in common areas
[EX A]: holding over

[EX Q]: County Reg’l Planning Comm’n v. Hamilton Ban zure beyond its lawful duration, such theft violates the Fourth Amendment. See Nelson v. Streeter, 16 F.3d 145, 151 (7th Cir.1994). The remaining question is whether Colaprete’s Fourth Amendment right against having his property converted following a search was clearly established when the alleged conversion occurred. The Seventh Circuit has held that the existence of this right is “[s]o obvious ... that we do not think the absence of case law can establish a defense of immunity.” Id. We respectfully disagree. This court has never applied the Fourth Amendment in this manner, and Supreme Court precedent tilts slightly against the existence of any constitutional right against theft during the course of a search. See Hudson, 468 U.S. at 533(<HOLDING>). Moreover, the Sixth Circuit has held that the 
 Holding statements: (A) holding postdeprivation remedy is adequate even when deprivation was intentional (B) holding that doctrine does not violate due process (C) holding that theft by prison guards does not violate due process when postdeprivation remedy exists (D) holding that deprivation of property does not violate due process if a meaningful postdeprivation remedy is available and explaining that state tort actions are meaningful postdeprivation remedies (E) holding that a prison guards intentional destruction of a prisoners possessions did not give rise to a federal due process claim because state law provided an adequate postdeprivation tort remedy
[EX A]:
holding postdeprivation remedy is adequate even when deprivation was intentional