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.

Example Input: 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
Example Output: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

Example Input: Covenant Media of South Carolina, LLC v. City of North Charleston, 493 F.3d 421 (4th Cir.2007) (city regulation was revised during the litigation to include a time limit for reviewing permits; however the court still found standing because Covenant had suffered an injury by the City's application of the original unconstitutional ordinance that is redressable at least by nominal damages); Boulder Sign Co. v. City of Boulder City, Nevada, 281 Fed.Appx. 701 (9th Cir.2008) (City passed an ordinance banning all billboards while sign company was challenging size restrictions of the original ordinance; court found no standing because sign company's alleged injury cannot be redressed by a favorable decision.); Coral Springs St. Sys. v. City of Sunrise, 371 F.3d 1320 (11th Cir.2004) (<HOLDING>); Granite State Outdoor Adven, Inc. v.
Holding statements: (A) recognizing that the zoning code of a homerule city is a legislative enactment (B) recognizing that code is speech (C) recognizing that source code is speech but not reaching the object code issue (D) holding that the challenge to the sign code is moot because the original code was repealed and superseded and there was no reasonable likelihood the city would reenact the old code (E) holding that citys enforcement of the entire state penal code would not constitute a city policy because the city was required to follow state law
Example Output: recognizing that the zoning code of a homerule city is a legislative enactment

Example Input: to correct error are proper only after the entry of final judgment; any such motion filed pri- or to the entry of final judgment must be viewed as a motion to reconsider. See Citizens Indus. Group v. Heartland Gas Pipeline, LLC, 856 N.E.2d 734, 737 (Ind. Ct.App.2006) (explaining that "a party can only file a motion to reconsider with the court if the action remains in fieri " and "[i]f the trial court has issued a final judgment, the party must file a motion to correct errors rather than a motion to reconsider"), trans. denied; Stephens v. Irvin, 730 N.E.2d 1271, 1277 (Ind.Ct.App.2000) (treating a motion labeled a "Motion to Correct Error" filed before the entry of final judgment as a motion to reconsider), trans. denied; Hubbard v. Hubbard, 690 N.E.2d 1219, 1221 (Ind.Ct.App.1998) (<HOLDING>). This distinction is important because unlike
Holding statements: (A) holding that a motion to reconsider a section 2255 ruling is available and that it is to be treated asa rule 59e motion if filed within 10 days of entry of the challenged order (B) holding that rule 59e applies to a motion to reconsider (C) holding that a motion to intervene filed after final judgment should have been granted (D) holding that the courts denial of either a motion to dismiss or a motion for summary judgment is not a final judgment and is not reviewable (E) holding that a motion to reconsider filed after the entry of final judgment must be considered a motion to correct error
Example Output:
holding that a motion to reconsider a section 2255 ruling is available and that it is to be treated asa rule 59e motion if filed within 10 days of entry of the challenged order