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.

Q: Apr. 14, 2011). Accord Wright v. Goord, 554 F.3d 255, 274 (2d Cir.2009) (dismissing a retaliation claim whose only causal basis was a letter that plaintiff wrote many weeks before the allegedly retaliatory acts, implicating officers other than named defendants). See also Def. Mem. at 11 ("[A] claim that one defendant took action against the plaintiff in retaliation for a complaint made against a different [officer] [should be] viewed with particular skepticism."). 40 . Def, Mem. at 17. 41 . See id. (citing exclusively to Eighth Amendment cases). 42 .Id. 43 . See Wright, 554 F.3d at 274. 44 . Def. Mem. at 18. 45 . Def. Mem. at 19. 46 . Davis, 320 F.3d at 353. 47 . Dawes, 239 F.3d at 493. 48 . Compare Hofelich v. Ercole, No. 06 Civ. 1369, 2010 WL 1459740, at *2 (S.D.N.Y. Apr. 10, 2010) (<HOLDING>), with Rembert v. Cheverko, No. 12 Civ. 9196,
Holding statements: (A) holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim (B) holding that a verbal threat of being fired is not an adverse employment action for purposes of title vii (C) holding that verbal threats if they are specific can constitute adverse action for retaliation purposes (D) holding that a suspension with pay may constitute materially adverse action for the purposes of retaliation claims depending on the facts of the case (E) holding that a transfer of job duties can constitute an adverse employment action

A: holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim
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Q: Erickson-Puttmann concedes that her Title VII claim against Gill fails because Gill was not her employer. See e.g., Bonomolo-Hagen v. Clay Central-Everly Community Sch. Dist., 121 F.3d 446, 447 (8th Cir.1997) ("Our Court quite recently has squarely held that supervisors may not be held individually liable under Title VII." (citing Spencer v. Ripley County State Bank, 123 F.3d 690, 691-92 (8th Cir.1997) (per cu-riam))). Lenhardt v. Basic Inst, of Tech., Inc., 55 F.3d 377, 381 (8th Cir.1995) (noting that "[e]very circuit that has considered the issue ultimately has concluded that an employee, even one possessing supervisory authority, is not an employer upon whom liability can be imposed under Title VII."); Smith v. St. Bernards Reg'l Med. Ctr., 19 F.3d 1254, 1255 (8th Cir. 1994) (<HOLDING>). Therefore, the court concludes that summary
Holding statements: (A) holding that individual employees are not liable under title vii (B) holding that individual defendants may not be held liable for violations under title vii (C) holding individual employees may be liable under title vii (D) holding that a title vii plaintiff could not hold coworkers liable in their individual capacities under title vii (E) holding that there is no individual liability under title vii

A: holding that individual employees are not liable under title vii
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Q: on the foregoing, we conclude that Layman's and Sparks' sentences are inappropriate. Like Quiroz, ten years of Layman's sentence should be suspended to probation and five years of Sparks' sentence should be suspended to probation. IV. Sufficiency of the Evidence Lastly, Sparks argues that there is insufficient evidence to support his felony murder conviction because he did not enter the house. However, Sparks, whose cursory argument is less than a page long, cites no cases in support of his claim. Sparks has therefore waived this issue on appeal. See Indiana Appellate Rule 46(A)(8)(a) (stating that each argument must be supported by citations to authorities, statutes, and the appendix or parts of the record on appeal relied on); Smith v. State, 822 N.E.2d 193, 202-03 (Ind.Ct.App.2005) (<HOLDING>), trans. denied. Waiver notwithstanding, we
Holding statements: (A) holding that when an appellant fails to offer an argument on an issue that issue is abandoned (B) holding that a claim is waived on appeal when not supported by citation to relevant authority (C) holding that a party waives an argument if the party fails to elaborate or provide any citation of authority in support of the argument (D) holding when a party fails to provide arguments or supporting authority for his assertion the party is deemed to have abandoned the issue (E) holding that an issue is waived when a party fails to provide adequate citation to authority

A:
holding that when an appellant fails to offer an argument on an issue that issue is abandoned
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