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.

[Q]: pain and suffering, demonstrated his reliance on a prohibited tort theory); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242-43 (1988) (declining to consider an intentional infliction of emotional distress action, in which the plaintiff sought damages for “anguish, shock, nervousness, and depression,” because the abolition of claims for alienation of affections was intended to preclude these allegations); see also Wilson v. Still, 819 P.2d 714, 716 (Okla.1991) (finding a suit for intentional infliction of emotional distress was barred because the plaintiff basically sued the defendant for “wil-fully taking away her husband” and stating the legislature immunized that conduct from tort liability). But see Erickson v. Christenson, 99 Or.App. 104, 781 P.2d 383, 385-86 (1989) (<HOLDING>), appeal dismissed, 311 Or. 266, 817 P.2d 758 
 Holding statements: (A) holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute (B) holding a plaintiff could proceed on a claim alleging intentional infliction of emotional distress because the alleged losses were different from those for seduction but also stating plaintiffs previously suing for seduction could recover for damage to character and reputation as well as for mental anguish and pecuniary losses (C) recognizing validity of cause of action for intentional infliction of emotional distress (D) holding that police officers were immune from liability for damages resulting from alleged intentional infliction of emotional distress (E) recognizing the tort of intentional infliction of emotional distress
[A]: holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute


[Q]: claims that respondent was aware World Bowling was purchasing the bowling alley from appellants but was never informed of the details of the purchase. We reject respondent’s contention that it could not have actual knowledge of appellants’ misfiled U.C.C.-l because any details it knew about the purchase of the bowling alley and its contents took place before the U.C.C.-l was filed. First, respondent had notice that the bowling alley contents were encumbered because it was involved with the sale until the time of closing. Second, the plain language of section 386.9-401(2) does not require that knowledge of the contents be gained only after the U.C.C.-l is misfiled and we may not add this requirement to the statute. Martinco v. Hastings, 265 Minn. 490, 497, 122 N.W.2d 631, 638 (1963) (<HOLDING>). Finally, both the district court and 
 Holding statements: (A) holding that the courts cannot supply that which the legislature purposely omits or inadvertently overlooks (B) holding that whether the legislature has complied with article iii section 61 of the texas constitution which states that the legislature shall provide suitable laws for the administration of workers compensation insurance for municipalities is a political question committed to the legislature (C) holding that when the legislature enacts a statute it is presumed that the legislature is aware of existing statutes (D) holding that a statutory right is a creature of the legislature and does not exist where the legislature has not acted (E) holding that in order for there to be state debt in the constitutional sense one legislature in effect must obligate a future legislature to appropriate funds to discharge the debt created by the first legislature
[A]: holding that whether the legislature has complied with article iii section 61 of the texas constitution which states that the legislature shall provide suitable laws for the administration of workers compensation insurance for municipalities is a political question committed to the legislature


[Q]: (9th Cir.1995). Finally, we dispose of appellees’ argument that Henderson v. Terhune, 379 F.3d 709 (9th Cir.2004), precludes a RLUIPA claim when the complaint cites only the First Amendment. There, we “expressed] no opinion about whether” the challenged regulation violated RLUIPA because the inmate “brought his claim under the First Amendment, not the RLUI-PA.” Id. at 715 n. 1. Appellees’ reliance on Henderson is misplaced, because at no point did the plaintiff there even assert a RLUIPA claim. See id. at 711-12. Here, Alvarez specifically raised his RLUIPA theory in his post-complaint filings, thereby apprising appellees before summary judgment that he was claiming relief under both the First Amendment and RLUIPA. See Coleman v. Quaker Oats Co., 232 F.3d 1271, 1292-94 (9th Cir.2000) (<HOLDING>). Appellees had notice of and the opportunity 
 Holding statements: (A) holding that plaintiffs could not proceed with different theory of liability after close of discovery when defendant would be prejudiced by inability to develop newly relevant evidence and defenses (B) holding only defenses that would be valid in rendering state can be relied upon by courts of another state (C) holding that a discovery exception to a statute of limitation applies only to the discovery of facts not discovery of the law (D) holding that the plaintiffs had relied on illinois law because they could have filed in a different forum having a different statute of limitations (E) holding that only justification defenses would be recognized
[A]:
holding only defenses that would be valid in rendering state can be relied upon by courts of another state