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.

Standards Enforcement v. Dillingham Constr., Inc., 519 U.S. 316,-, 117 S.Ct. 832, 838, 136 L.Ed.2d 791 (1997) (citations omitted). The Supreme Court has held that ERISA preempts state common law tort and contract causes of action asserting improper processing of a claim for benefits under an insured employee benefit plan. Pilot Life, 481 U.S. at 57. The detailed provisions of ERISA § 502(a) set forth a comprehensive civil enforcement scheme that “would be completely undermined if ERISA-plan participants and beneficiaries were free to obtain remedies under state law that Congress rejected in ERISA.” Id. at 54, 107 S.Ct. 1549. Similarly, we have held that state law tort and contract claims as well as violations of a state insurance statute are preempted by ERISA. Tingey, 953 F.2d at 1131 (<HOLDING>). In a factually similar case, we held that 
 Holding statements: (A) holding that erisa preempts claims for breach of contract breach of duty of good faith and fair dealing and negligent misrepresentations (B) holding plaintiffs causes of action for breach of contract breach of the duty of good faith and fair dealing intentional infliction of emotional distress and violations of the arizona insurance code were preempted by erisa (C) holding that erisa  514a preempts claims for breach of contract breach of duty of good faith and fair dealing negligence and intentional infliction of emotional distress (D) holding that a claim for intentional infliction of emotional distress was preempted where it was based on the same conduct as a preempted claim for breach of the covenant of good faith and fair dealing (E) holding that the plaintiffs state common law causes of actions for breach of contract and breach of the duty of good faith and fair dealing as well as a statutory cause of action for unfair insurance practices under the california insurance code were preempted by erisa
holding that erisa preempts claims for breach of contract breach of duty of good faith and fair dealing and negligent misrepresentations

court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts
holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort

be proved in support of the claim. See id. It is well-settled that North Carolina law precludes a plaintiff from recovering more than one-satisfaction for the same injury, caused by different parties. “Both reason and justice decree that there should be collected no double compensation, or even overcompensation, for any injury, however many sources of compensation there may be.... Any amount paid by anybody, whether they be joint tort-feasors or otherwise, for and on account of any injury or damage, should be held for a credit on the total recovery in any action for the same injury or damage.” Holland v. Southern Public Utilities Co., Inc., 208 N.C. 289, 292, 180 S.E. 592, 593-94 (1935). See also Chemimetals Processing, Inc. v. Schrimsher, 140 N.C.App. 135, 138, 535 S.E.2d 594 (2000) (<HOLDING>); Chisholm v. UHP Projects, Inc., 205 F.3d 731, 
 Holding statements: (A) holding that duplication of damages or double recovery is impermissible (B) holding that the avoidance powers provide for recovery only if the recovery is for the benefit of the estate (C) holding that recovery is limited to actual compensatory damages (D) holding that it is wellsettled that although a plaintiff is entitled to full recovery for its damages it is not entitled to a double recovery for the same loss or injury (E) holding that it is not

holding that duplication of damages or double recovery is impermissible