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.

[EX Q]: 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
[EX A]: holding district courts order postponing ruling on defendants qualified immunity defense was immediately appealable

[EX Q]: is minimized if officers exercise unquestioned command of the situation. Id., 129 S.Ct. at 786-87. Here, evidence supports the district court’s finding that Hollins’s behavior gave the police reasonable suspicion to believe that Hollins was armed and dangerous when they searched him. First, Hollins repeatedly refused to follow instructions to keep his hands in plain view, and he would slide his hands toward his waist while he was seated in the vehicle. Nervous, evasive behavior, which Hollins exhibited, is one of several factors which may be pertinent in determining reasonable suspicion. See United States v. Gordon, 231 F.3d 750, 756 (11th Cir.2000). Second, Hollins repeatedly refused to obey an officer’s instruction to exit the vehicle. See Maryland, 519 U.S. at 410, 117 S.Ct. at 884 (<HOLDING>). Third, Hollins repeatedly disregarded an 
 Holding statements: (A) holding that police officer may order passengers to remain in vehicle with hands up during traffic stop (B) holding that it is permissible for an officer to order the occupants out of a vehicle during a lawful stop (C) holding an officer may order a passenger to get out of a car during a traffic stop and may frisk a passenger for weapons if the officer reasonably suspects the passenger is armed and dangerous (D) holding that an officer may order a passenger out of a vehicle during a stop for a traffic infraction (E) holding that a traffic stop is reasonable under the fourth amendment when police have probable cause to believe a traffic infraction has occurred
[EX A]: holding that police officer may order passengers to remain in vehicle with hands up during traffic stop

[EX Q]: pregnant woman consists of a person other than the woman injuring a pregnant woman in the commission of a felony causing her to suffer a miscarriage or stillbirth as a result of that injury” (§ 30-3-7(A)), defining “miscarriage” as “the interruption of the normal development of the fetus, other than by a live birth” (§ 30-3-7(B)(1)), and defining “stillbirth” as “the death of a fetus prior to the complete expulsion or extraction from its mother” (§ 30-3-7(B)(2))); see also NMSA 1978, § 66-8-101.1 (1985) (injury to pregnant woman by vehicle). These provisions 'indicate that when the Legislature intends to include fetuses within the protection of a criminal statute, it does so specifically. {9} This Court may not expand the meaning of “human being” to include an unborn vi 0, 713 (1992) (<HOLDING>); Reinesto v. Superior Court of Ariz., 182 
 Holding statements: (A) holding that mother could not be prosecuted under child abuse statute for prenatal use of heroin (B) holding a woman may be prosecuted for child neglect and endangering a child for prenatal substance abuse (C) holding a mother not criminally liable for child endangerment for ingesting heroin while pregnant (D) holding that mother may not be prosecuted criminally for child endangerment for prenatal substance abuse (E) holding a mother may not be held criminally liable under a reckless endangerment statute for the effect that prenatal ingestion of a controlled substance may have on her child pre or postbirth
[EX A]:
holding that mother could not be prosecuted under child abuse statute for prenatal use of heroin

