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.

in nature and may be waived if not timely raised. Section 1445(c) applies to prohibit the removal of a civil action arising under the workmen’s compensation laws of a state. It does not prohibit federal district court’s from exercising supplemental jurisdiction under § 1367. The state worker compensation statutes themselves may affect the court’s jurisdiction by requiring claims to be filed with an administrative agency. However, such is not the case for claims of retaliatory discharge for exercising rights under Michigan’s WDCA. As noted above, the expeditious and inexpensive procedures found in Michigan’s WDCA are not utilized when an employee alleges retaliatory discharge. Such a claim is treated like any other tort and can be filed in state court. See Delke, 460 N.W.2d at 327-28 (<HOLDING>); see also Lamoria, 584 N.W.2d at 600; Chiles 
 Holding statements: (A) recognizing the tort of retaliatory discharge (B) holding the retaliation claim did arise under states workers compensation laws (C) recognizing retaliatory discharge tort implied by the workers compensation act (D) holding that retaliation claim did not arise under states workers compensation laws (E) holding that the bureau of workers disability compensation did not have jurisdiction to hear retaliation claims and explaining that the michigan legislatures intent was not to create an administrative remedy for retaliatory discharge
recognizing the tort of retaliatory discharge

the statute.” 167 F.3d at 992 (citing Haun, 90 F.3d at 1100; United States v. Cavalier, 17 F.3d 90, 93 (5th Cir.1994); United States v. Paramo, 998 F.2d 1212, 1217-18 (3d Cir.1993)). See also United States v. Valuck, 286 F.3d 221, 226 (5th Cir.2002) (reaffirming the holding in Cavalier that “the cashing of an illegally obtained check can promote the completion of an underlying unlawful act”). The Federal Express packages at issue in the money laundering counts contained checks fraudulently obtained by IDM. A rational trier of fact could reasonably conclude that the transfer of the checks from Barbados to New York and the negotiation of those checks promoted the underlying mail fraud scheme, and that by facilitating the negotiation of the checks Bo 88831, at *2 (6th Cir. Mar. 17, 1994) (<HOLDING>); United States v. Jackson, 935 F.2d 832, 842 
 Holding statements: (A) recognizing exception to application requirement when employer does not notify employees of available promotion and does not provide formal mechanism for expressing interest in promotion (B) holding no offense of attempted seconddegree murder where statute allows conviction without proof of intent to kill (C) holding that promotion and concealment are alternative bases for a money laundering conviction proof of intent to accomplish either will suffice (D) holding that it is the fact of concealment and not the intent to conceal that is prohibited under 49 usc  1472f (E) holding that concealment is just one factor to consider and is not a mandatory element
recognizing exception to application requirement when employer does not notify employees of available promotion and does not provide formal mechanism for expressing interest in promotion

claim did not accrue until the moment of execution. McNair deemed such a time-of-harm accrual principle to have no application “where the ultimate injury is reasonably likely and wholly foreseeable.” 515 F.3d at 1174. The court went on to explain, “It is clear a capital litigant may file suit and obtain injunctive relief long before he is executed.” Id. After detailed analysis of various alternative dates, the McNair panel concluded that the appropriate accrual date for a method-of-execution challenge was the date that Alabama’s execution protocol became applicable to the plaintiff because by that time “the facts which would support a cause of action should have been apparent to any person with a reasonably prudent regard for his rights.” Id. at 1177; see also Crowe, 528 F.3d at 1293 (<HOLDING>). A similar conclusion was reached in Lovett v. 
 Holding statements: (A) holding that methodofexecution challenge accrued for limitations period when after direct review of his convictions had been completed crowe became subject to the method of lethal injection that he chal lenges (B) holding that the plaintiff was required to arbitrate his claim which accrued before he became bound by the arbitration rules of the new york stock exchange because he was fully aware of the existing claim at the time he became a member of the exchange and became bound by its arbitration rules (C) holding that the statute of limitations accrued when the minors father was appointed his guardian and not when the minor became comatose (D) holding that a conviction became final when the ninetyday period to seek direct review from the  supreme court by way of certiorari expired (E) holding that an attorneys cause for services rendered over a period of time accrued when his services had been completely performed

holding that the plaintiff was required to arbitrate his claim which accrued before he became bound by the arbitration rules of the new york stock exchange because he was fully aware of the existing claim at the time he became a member of the exchange and became bound by its arbitration rules