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.

Input: Consider Input: 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

Output: holding that arguments raised for the first time in a reply brief are forfeited

Input: Consider Input: on the conditions stated in the publicly-filed limited partnership certificate. We affirm the appellants' liability under 106(l)(b). The certificates of limited partnership for TSG, TMG, and TSG 80 all state that, if necessary to satisfy the partnership's recourse obligations, each limited partner has agreed, upon demand, to make an additional capital contribution of up to three times the limited partner's original investment. These certificates were recorded publicly in New York County. Accordingly, the capital of the Limited Partnerships upon which creditors properly could rely included the limited partners' stated ob ligation to make additional capital contributions. See Arno Management Corp. v. 115 East 69th Assocs., 173 A.D.2d 258, 260, 569 N.Y.S.2d 656, 657 (1st Dept.1991) (<HOLDING>). Section 106(l)(b) explicitly provides a means
Holding statements: (A) holding that limited partner does not have standing to sue for injuries to partnership that merely diminish value of that partners interest (B) holding that appellate jurisdiction is limited to the issues contained in the certificate of appealability (C) recognizing partnership by estoppel only with respect to claims by persons who have reasonably relied upon outward representations of partnership (D) recognizing that same principle applies where defendant is general partner of limited partnership which in turn is general partner of limited partnership with contacts with state (E) holding that the information contained in the certificate of limited partnership binds the partnership and the partners with respect to third parties

Output: holding that limited partner does not have standing to sue for injuries to partnership that merely diminish value of that partners interest

Input: Consider Input: GARY W. LYNCH, P.J., and NANCY STEFFEN RAHMEYER, J., concur. 1 .It is the duty of this Court to determine the propriety of the appeal. Krause v. Tullo, 835 S.W.2d 488, 490 (Mo.App. S.D.1992). J.L.G. was included in the caption in E.W.G.'s appeal and a separate "Notice of Appeal" was filed for her. However, E.W.G. is not J.L.G.'s biological father. The parental rights of J.L.G.'s biological father were terminated on April 17, 2000. The only action the trial court took regarding J.L.G. was termination of the parental rights of J.L.G.'s biological mother ("Mother"). Mother is not a party to this appeal; therefore, we dismiss the separate Notice of Appeal for J.L.G. in that E.W.G. has no standing to assert parental rights for her. See In re Q.M.B., 85 S.W.3d 654, 662 (Mo.App. W.D.2002) (<HOLDING>). We refer to evidence about Mother and/or
Holding statements: (A) holding that as a matter of contract no party can be forced to arbitrate unless that party has entered into an agreement to do so (B) holding that party standing in loco parentis has standing to seek custody of child (C) holding that an evicted plaintiff has no legal interest in property and therefore has no standing to bring a cercla claim (D) holding a party has no standing to appeal unless he or she is an aggrieved party an individual who is not a parent in the eyes of the law has no legal interest in the child and therefore has no standing to appeal (E) holding that prevailing party has no standing to appeal
Output: holding that as a matter of contract no party can be forced to arbitrate unless that party has entered into an agreement to do so