I have some creative kids. Here's an example of one of their answers for sketching a plane with noncollinear points and a line segment. (NOTE: He didn't get the credit for the points not in a line and he didn't finish the test. At least he feels good about the artwork he drew for me!)
So would that be a 2, 3, or 4. I could see it being a 4 if there were 2 separate planes.
*** Got another answer similar from the same class. This kid did better on it though. He got the 2 separate planes and the guys love that pics of their test are on my teaching blog!