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.
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Question: strengthen, not displace, any existing remedies employees may. have at law.” Id. It is clear from these excerpts that the STAA was not enacted to completely preempt state law remedies for retaliation against an employee who refuses to violate safety provisions. See Todd v. Frank’s Tong Service, Inc., 784 P.2d 47, 49-50 (Okla.1989) (noting that Congressional intent surrounding enactment of the STAA demonstrates that state law claims are not preempted); see also Parten v. Consolidated Freightways Corp., 923 F.2d 580, 583 (8th Cir.1991) (conclude ing that the Minnesota public policy statute was not an obstacle to the STAA and that Congress did not intend to occupy the entire field of interstate motor carriers); Whitworth v. TNT Bestway Transp., Inc., 914 F.Supp. 1434, 1436 (E.D.Tex.1996) (<HOLDING>); Dobberowsky v. Cryogenic Transp., Inc., 989 
 Holding statements: (A) holding texas exemption law was not preempted by erisa due to savings clause (B) holding that texas whistleblowers act was not preempted by the staa (C) holding a claim of a violation of the texas dtpa is preempted by the carmack amendment (D) holding that the age discrimination in employment act was not preempted by the nlra (E) holding that where the entity was incorporated in texas and the shareholders reside in texas and the bankruptcy case is pending in texas texas law  not arizona law  should be applied

Answer: holding texas exemption law was not preempted by erisa due to savings clause


Question: separate recording of the trust or declaration of trust. As there is no evidence on the face of the deeds indicating a. contrary intent, the Personal Representatives, pursuant to their fiduciary responsibilities, seek a declaration that, pursuant to section 689.07(1), Norman held fee simple title to the properties on the date of his death. These allegations are clearly sufficient under the plain language of the statute. See Raborn, 974 So.2d at 328 (stating that under section 689.07(1), a deed that simply refers to grantee as “trustee” conveys a fee simple estate, and applying the statute to find that deed at issue fell under “contrary intention” exception such that grantee held mere legal title as trustee); One Harbor Fin, Ltd. v. Hynes Props., LLC, 884 So.2d 1039 (Fla. 5th DCA 2004) (<HOLDING>); Heiskell v. Morris, 182 So.3d 714 (Fla. 1st 
 Holding statements: (A) holding that where grantee was named as trustee without identification of the beneficiaries or the nature and purposes of the trust and no trust agreement of record was identified the grantee received fee simple title (B) holding that debtor as grantor and trustee of a trust that held legal title to the property held a sufficient equitable interest in the property to claim it as exempt homestead where she resided on the property prepetition with the intent to maintain it as her primary residence (C) holding that trial court erred by granting surviving spouse fee simple title to estates exempt property (D) holding that trial court correctly applied section 689071 to find that grantee who held title as trustee owned property in fee simple absolute (E) holding that where individual held title to property as trustee but gave mortgage to bank in her individual capacity a title reference on the mortgage to the deed into her as trustee provided constructive notice that the mortgage was supposed to be from the individual as trustee or at the least that the holder of a subsequent interest would not be a bona fide purchaser

Answer: holding that where grantee was named as trustee without identification of the beneficiaries or the nature and purposes of the trust and no trust agreement of record was identified the grantee received fee simple title


Question: at *13-*14. We overrule Palavan’s third and fifth issues. Declaratory Judgment Action In his fourth issue, Palavan argues the county court improperly granted summary judgment on McCulley and TBW Development’s declaratory judgment action. Even if we agreed with Palavan, however, he has failed to establish how he has been injured by a dismissal of McCulley and TBW Development’s declaratory judgment action. See CBS Outdoor, Inc. v. Potter, No. 01-11-00650-CV, 2013 WL 269091, at *17 (Tex.App.—Houston [1st Dist.] Jan. 24, 2013, pet. denied) (mem.op.) (“In order to obtain reversal on appeal, the appellant must show that it suffered harm as a result of an alleged error.”). We overrule Palavan’s fourth issue. Conclusion We affirm the judgment of the trial court. 1 . See Palavan (Tex.2008) (<HOLDING>); Walling v. Metcalfe, 863 S.W.2d 56, 58 
 Holding statements: (A) holding that what constitutes a criminal instrument is determined by both its design or adaptation and its intended use (B) holding nature of motion is determined by its substance not its title (C) holding that because pleadings are to be liberally construed if the nature of the motion is clear from its substance an improper caption is not fatal (D) holding that possession of a controlled substance is a crime only if the defendant knowingly possesses the substance and has knowledge of the nature of that substance (E) holding that the economic substance of a transaction rather than its form determines its tax treatment

Answer:
holding that what constitutes a criminal instrument is determined by both its design or adaptation and its intended use