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: protected activity for purposes of the first element of a prima facie case and the second element is not disputed. "To establish a causal connection, a plaintiff must show that 'the decision-makers were aware of the protected conduct' and 'that the protected activity and the adverse employment action were not wholly unrelated.' " Gupta v. Fla. Bd. of Regents, 212 F.3d 571, 590 (11th Cir.2000) (internal citations omitted). "[A]t a mini mum, [a plaintiff] must show that the adverse act followed the protected conduct." Griffin v. GTE Fla., Inc., 182 F.3d 1279, 1284 (11th Cir.1999). In other words, the plaintiff must show a temporal link between a protected activity and an adverse employment action. See Sullivan v. Nat'l R.R. Passenger Corp., 170 F.3d 1056, 1060-61 (11th Cir.1999) (<HOLDING>); Griffin, 182 F.3d at 1281-82 (finding no
Holding statements: (A) holding causal link between alleged discriminatory remarks and adverse employment action insufficient (B) holding that a prima facie case of retaliation requires a causal link between the employees protected activity and the employers adverse employment action (C) holding that an intervening act of misconduct by the plaintiff can break the causal link between the protected conduct and the adverse employment action (D) holding that no causal link existed between protected activity in february 1994 and adverse employment actions in late 1994 and early 1995 (E) holding that five weeks between protected activity and adverse employment action insufficient to establish a causal connection
Example Output: holding causal link between alleged discriminatory remarks and adverse employment action insufficient

Example Input: 878 F.2d at 874; Geter v. Fortenberry, 849 F.2d 1550, 1553-54 (5th Cir.1988); Jacquez v. Procunier, 801 F.2d 789, 791-93 (5th Cir.1986); and Elliott v. Perez, 751 F.2d 1472, 1480-82 (5th Cir.1985). 115 . See Gaines v. Davis, 928 F.2d at 707; Brown v. Glossip, 878 F.2d at 874 n. 5; Geter v. Fortenberry, 849 F.2d at 1559-60; and Lion Boulos v. Wilson, 834 F.2d 504, 507-09 (5th Cir.1987). 116 . See Jackson v. City of Beaumont Police Department, 958 F.2d at 621; and Jacquez v. Procunier, 801 F.2d at 793. 117 . Jackson v. City of Beaumont Police Department, 958 F.2d at 620; Nieto v. San Perlita ISD, 894 F.2d 174, 177-78 (5th Cir.1990); and Jacquez v. Procunier, 801 F.2d at 791. See also Babb v. Dorman, 33 F.3d 472, 477 (5th Cir.1994); and James v. Sadler, 909 F.2d 834, 838 (5th Cir.1990), (<HOLDING>). 118 . Lion Boulos v. Wilson, 834 F.2d at 509;
Holding statements: (A) recognizing that statute of limitations questions may be resolved on a motion to dismiss (B) holding that the existence of genuine issues of material facts render not appealable a pretrial denial of summary judgment on the issue of qualified immunity (C) holding that questions regarding qualified immunity are resolved on the face of the pleadings and with limited resort to pretrial discovery (D) holding that defendants are not entitled to qualified immunity (E) holding that where defendant claiming qualified immunity relies on facts that are in dispute qualified immunity cannot be granted
Example Output:
recognizing that statute of limitations questions may be resolved on a motion to dismiss