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: v. Fortis Benefits Ins. Co., 116 F.Supp.2d 937, 950-51 (M.D.Tenn.2000). As other circuits have recognized, the treating physician rule is a standard that was developed in the Social Security context requiring the administrative law judge to give deference to the opinions of a claimant’s treating physician when determining the claimant’s eligibility for benefits. See, e.g., Regula, 266 F.3d at 1139; see also Peabody Coal Co. v. Groves, 277 F.3d 829, 833-35 (6th Cir.2002) (applying the “treating physician presumption” in a Black Lungs Benefit case holding that an AL J may place greater weight on the opinion of a claimant’s treating physician than those of non-treating physicians). Several circuits have adopted the treating physician rule in an ERISA context. Regula, 266 F.3d at 1139 (<HOLDING>); Donaho v. FMC Corp., 74 F.3d 894, 901 (8th 
 Holding statements: (A) holding that vicarious liability claim against union based on medical malpractice of treating physician is not preempted by erisa (B) holding that erisa benefits are not property of the estate (C) holding that an erisa plan administrator is not bound by an ssa disability determination when reviewing a claim for benefits (D) holding that where a treating physicians opinion is contradicted by a consulting physician the alj must explain on the record the reasons for rejecting the opinion of the treating physician (E) holding as a matter of first impression that the treating physician rule is applicable in the context of a disability benefits determination under erisa
Example Output: holding that vicarious liability claim against union based on medical malpractice of treating physician is not preempted by erisa

Example Input: are reasonably susceptible to two different interpretations, and therefore are ambiguous. See Westchester Surplus Lines Ins. Co. v. Keller Transp., Inc., 382 Mont. 72, 365 P.3d 465, 470 (Mont. 2016). Montana law construes ambiguous provisions “against the insurer and in favor of extending coverage.” Id. We therefore reject United Fire’s argument that the Premises Endorsements limit coverage to incidents that occurred on the St. George premises. Because the Premises Endorsements purport to cover claims “arising out of ... the use of’ the St. George premises, they are sufficiently capacious to include coverage for bodily injury in Montana that flows from or grows out of the use of the St. George premises. See State Farm Mut. Auto. Ins. Co. v. Ferrin, 311 Mont. 155, 54 P.3d 21, 23 (2002) (<HOLDING>). Thus, United Fire had a duty to defend 
 Holding statements: (A) holding that an arising out of exclusion applies to claims flowing from or growing out of the excluded activity (B) holding that the phrase arising out of the use is ambiguous and interpreting it as originating from or growing out of or flowing from (C) holding that insurance provisions excluding damage arising out of the use of land motor vehicles subject to registration and damage arising out of the use of land motor vehicles if the injury or damage occurs away from the insured premises were ambiguous because together they could be read in four different ways (D) holding claim for injuries arising out of use of truck and not from negligent supervision excluded from coverage by auto exclusion in commercial general liability policy no claim that language in policy was ambiguous or unclear (E) holding phrase arising out of the ownership maintenance or use of a motor vehicle as contained in um policy should be given same interpretation as in automobile liability policies
Example Output: holding that an arising out of exclusion applies to claims flowing from or growing out of the excluded activity

Example Input: promise to sell [him] Unit 7S,” which he considers “a unique property.” In addition, he contends that what “had been a refundable deposit on another unit in Boston is now non-refundable.” This is reportedly because he “has stopped looking at other properties in Boston and the opportunity to purchase many of these potential properties likely no longer exists.” The Rule 56 materials submitted to this court do not support these contentions. As mentioned in the background supra, Trinity Place has confirmed, in response to a subpoena, that Albrecht has already entered into a P&S agreement with them. It cannot be said, therefore, that Albrecht has suffered the harms he complains of. These facts are simply not sufficient to support an estoppel. Compare Levin v. Rose, 302 Mass. 378, 382 (1939) (<HOLDING>) (citations omitted). Facts Alleged by Albrecht 
 Holding statements: (A) holding that even wisconsin which has one of the broadest coverages of the economic loss doctrine would not apply it to bar an action for the rescission of a contract (B) holding that the statute of frauds is not a bar where the denial of relief to one who has been misled to his harm would cause an unjust and unconscientious injury and loss (C) holding that loss of customers and resulting injury to goodwill can constitute irreparable harm that is not compensable by an award of money damages (D) holding that the plain language of this section requires the denial of relief for a petitioner who has finished serving his sentence (E) holding that a plaintiffs claim of injury stemming from alleged procedural harm is insufficient to ground standing where the harm is uncoupled from any injury in fact or tied only to an undifferentiated injury common to all members of the public
Example Output:
holding that even wisconsin which has one of the broadest coverages of the economic loss doctrine would not apply it to bar an action for the rescission of a contract