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.
--------
Question: 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

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

Question: of other courts have concluded, outside the RICO and Clayton Act context, that "by reason of" should be read to require only "but for" rather than proximate causation. See, e.g., Gross v. FBL Fin. Servs., Inc., 557 U.S. 167, 129 S.Ct. 2343, 2350, 174 L.Ed.2d 119 (2009) ("The words 'because of' mean 'by reason of: on account of.' Thus, the ordinary meaning of the ADEA's requirement that an employer took adverse action 'because of age is that age was the 'reason' that the employer decided to act. To establish a disparate-treatment claim under the plain language of the ADEA, therefore, a plaintiff must prove that age was the 'but-for' cause of the employer's adverse decision." (citations omitted) (emphasis added)); Robinson Knife Mfg. Co. v. C.I.R., 600 F.3d 121, 131-32 (2d Cir. 2010) (<HOLDING>); Spirtas Co. v. Ins. Co. of Pa., 555 F.3d 647,
Holding statements: (A) holding that in 26 cfr 1263ale3i the language directly benefit or are incurred by reason of boils down to a butfor causation test (B) holding that fees incurred by debtor were not in the nature of support (C) holding in an appeal from a postanswer default judgment that third prong of craddock test required appellant to offer to reimburse appellee for legal expenses he incurred in obtaining default judgment even though most of the fees incurred had not been paid (D) holding that pursuant to the eaja courts may not award expenses of an attorney that are not incurred or expended solely or exclusively in connection with the case before the court (E) holding a tribe subject to 1 a tax on the use of certain highway motor vehicles 26 usc 4481a 2 a tax on diesel fuel used in highway vehicles 26 usc 4041a 3 a tax on special fuels used in motor vehicles 26 usc 4041b and 4 a tax on manufacturing in this case a truck chassis assembled by the tribe 26 usc 4061a 4218a

Answer: holding that fees incurred by debtor were not in the nature of support

Question: we find that there is a reasonable interpretation of the statutes involved that avoids an inconsistency and gives effect to both statutes. Plaintiffs cause of action is based on the Act. As such, the only limitations period applicable to her claim is the two-year statute of limitations period found in section 2 of the Act. Thus, plaintiff had two years from the date of her husband's death to file a wrongful death action provided that plaintiffs decedent had a claim that was not time-barred at the time of his death. For purposes of determining whether plaintiffs decedent had a claim that was time-barred at the time of his death, we use the limitations period found in section 13 214(a), which applies to construction d 621, 628 (1989), aff'd on other grounds, 146 Ill. 2d 477 (1992) (<HOLDING>). Plaintiff also finds support for her position
Holding statements: (A) holding that statute of limitations for contribution actions found in section 13 204 of the code applies over limitations period for malpractice actions found in section 13 212 of the code where the plaintiffs complaint was based solely on contribution act ill rev stat 1985 ch 70 par 301 et seq section 13 204 is more specific than section 13 212 (B) holding that the limitations period in section 13 214a takes precedence over the limitations period for personal injuries found in section 13 202 of the code (C) holding that limitations period in section 13 214a of the code applies over limitations period for contribution actions found in section 13 204 of the code because former provision is more specific (D) holding that the then twoyear statute of limitations for constructionrelated actions found in section 13 214a of the code applies over the fiveyear statute of limitations period for certain actions found in section 13 205 of the code (E) holding merck applies to section 13 of the securities act

Answer:
holding that the limitations period in section 13 214a takes precedence over the limitations period for personal injuries found in section 13 202 of the code