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.

[EX Q]: 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
[EX A]: recognizing the tort of retaliatory discharge

[EX Q]: This Court has reviewed these decisions and is in agreement with their reasoning and conclusions that the public policy exception does not give rise to a protected property interest in continued employment in this case. Likewise, the implied covenant is not the source of a protected property interest. The implied covenant of good faith and fair dealing applies to at-will employment and affords an employee the right to be dealt with fairly and in good faith. See Cantwell v. City of Boise, 146 Idaho 127, 191 P.3d 205, 213-14 (2008). Breach of the covenant may give rise to an action for wrongful termination but it does not convert at-will employment to term employment nor form the basis for a protected property interest. See Hollister v. Forsythe, 22 F.3d 950, 952-52 (9th Cir.1994) (<HOLDING>); Willnerd v. Sybase, Inc., No. 
 Holding statements: (A) recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate (B) recognizing cause of action for implied covenant of good faith and fair dealing in atwill employment contract (C) holding an implied covenant of good faith and fair dealing was insufficient to create a property interest in continued employment under montanas statutory scheme for at will employment (D) holding that the implied covenant of good faith and fair dealing is limited to performance under a contract (E) recognizing that evidence of breach of implied covenant of good faith and fair dealing may support punitive damages
[EX A]: recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate

[EX Q]: doctrine is extended to instances in which “the possessor knows that children too young to appreciate such dangers are likely to trespass on his land.” The dissent cites a number of cases from foreign jurisdictions to the effect that water is an obvious danger to all children. These cases are not consistent with our own precedent, which has rejected blanket rules. Further, other courts across the country have reached the opposite conclusion. See, e.g., King v. Lennen, 53 Cal.2d 340, 1 Cal.Rptr. 665, 348 P.2d 98, 99-100 (1959) (emphasizing that “the circumstance that a condition giving rise to injury is common in character does not necessarily exclude liability, that the ability to appreciate danger varies with the age and mental capacity of the c 2d 43, 914 P.2d 728, 729 (1996) (<HOLDING>). We decline to adopt a categorical rule that 
 Holding statements: (A) holding that a store owner has a duty to protect invitees from foreseeable criminal acts (B) holding in a ease involving a child less than 3 years old that a landowner is not exempt from the duty to exercise reasonable care to protect invitees against potentially dangerous conditions on the land solely because the potential danger includes risks which are inherent in a natural body of water (C) holding that a residential landlord has no duty to protect invitees from foreseeable criminal acts (D) holding landowner had duty to provide security in parking lot to protect its invitees from criminal acts of third parties (E) holding a business owes a duty to protect invitees from reasonably foreseeable harm by third persons
[EX A]:
holding that a store owner has a duty to protect invitees from foreseeable criminal acts