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.

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
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

v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (2007). Kyler Road Home Charles first argues on appeal that the circuit court erred by not awarding him an interest in the home on Kyler Road. Although he acknowledges that Myra had acquired this property prior to the marriage, he asserts that he is entitled to an interest in the home because | ^marital funds were used to reduce the debt on the properly and to make improvements. Our definition of marital properly excludes property acquired before the marriage. Ark.Code Ann. § 9-12-315(b)(1) (Repl.2009). However, we have long held that a non-owning spouse is entitled to some benefit when marital funds have been expended to improve or reduce the debt on the other spouse’s nonmarital property. See Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (1993) (<HOLDING>); Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d 
 Holding statements: (A) holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property (B) holding that assets acquired subsequent to separation are not considered marital property absent evidence that spouse used marital property to obtain them (C) holding that separate property may become marital property if spouse donates it to marital unit with intent at time of donation that property become marital (D) holding that the trial court erred in finding that marital property was the former wifes separate property based on a nonseparation agreement in which the former husband purported to relinquish any interest in the marital property (E) holding that circuit court erred in failing to consider that marital property in the form of marital earnings was used to pay debt against nonmarital property
holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property

17 n. 7; see also Vinson v. Commonwealth, 258 Va. 459, 469, 522 S.E.2d 170, 177 (1999); Janis v. Commonwealth, 22 Va.App. 646, 651, 472 S.E.2d 649, 652, aff'd on reh’g en banc, 23 Va.App. 696, 479 S.E.2d 534 (1996); Penn v. Commonwealth, 13 Va.App. 399, 406-07, 412 S.E.2d 189, 193 (1991), aff'd per curiam, 244 Va. 218, 420 S.E.2d 713 (1992); Thompson v. Commonwealth, 10 Va.App. 117, 122, 390 S.E.2d 198, 201 (1990). The DUI statutes nowhere provide for a suppression remedy for procedural violations. Instead, Code § 18.2-268.11 states that a violation of the procedural steps of Code §§ 18.2-268.2 through 18.2-268.9 “shall go to the weight of the evidence and shall be considered with all the evidence in the case.” See Shumate v. Commonwealth, 207 Va. 877, 883, 153 S.E.2d 243, 247 (1967) (<HOLDING>); Snider v. Commonwealth, 26 Va.App. 729, 734, 
 Holding statements: (A) holding that a challenge to the weight of the evidence is waived for failure to present the issue first to the trial court (B) holding that procedural violations merely affect the weight of the evidence (C) holding that the postconviction court is the sole judge of the weight of the evidence and the credibility of witnesses (D) holding that new evidence must be evidence that is not merely cumulative (E) holding that allegation of procedural injury does not affect the issues of injury in fact or causation

holding that a challenge to the weight of the evidence is waived for failure to present the issue first to the trial court