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.

Example Input: 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
Example Output: holding that erisa preempts claims for breach of contract breach of duty of good faith and fair dealing and negligent misrepresentations

Example Input: venture” (FAC ¶ 39) are similarly insufficient. See Cannon v. Douglas Elliman, L.L.C., No. 06-CV-7092, 2007 WL 4358456, at *4 n. 3 (S.D.N.Y. Dec. 10, 2007) (“[Pjleading a joint venture does not trigger joint employer status because it is possible for joint ventures to separately employ different people .... ”); Hibbs-Rines v. Seagate Techs., L.L.C., No. 08-CV-5430, 2009 WL 513496, at *5 (N.D.Cal. Mar. 2, 2009) (“Plaintiff joint employer allegations are insufficient because they are legal conclusions, not factual allegations, .... While plaintiff is not required to conclusively establish that defendants were her joint employers at the pleading stage, plaintiff must at least allege some facts in support of this legal conclusion.”) cf. Patel v. Wargo, 803 F.2d 632, 635-36 (11th Cir.1986) (<HOLDING>). Plaintiffs arguments that these Defendants 
 Holding statements: (A) holding under flsa 29 usc  216c (B) holding that the authorization under 29 usc  1132a3 extends to a suit against a nonfiduciary party in interest to a transaction barred by 29 usc  1106a (C) holding under 29 usc  216c (D) holding that the finding that entities constitute a single enterprise under 29 usc  203r is separate and distinct from whether an entity is an employer under 29 usc  203d (E) holding that the defendant is in the best position to prove and should bear the burden of establishing its entitlement to an exemption under 29 usc  1108 from 29 usc  1106b erisas prohibited transactions provision
Example Output: holding under flsa 29 usc  216c

Example Input: of the composite tape is demonstrated by a July 11, 1994 letter written by Attorney Collins, who represented the City at the Civil Service Commission hearing, to Attorney Li-chten, Cignetti's counsel at the hearing. In that letter, Attorney Collins states that the tape was "made as part of the investigation.” The defendants’ have, moved to strike the letter. The motion is denied as moot. Although the letter itself has little or no evidentiary value, the defendants, as discussed above, have not established that they were engaging in prosecutorial functions when they prepared the tape. 8 . Several other Courts of Appeals have adopted similar exceptions to the broad immunity recognized in Briscoe v. LaHue. See Harris v. Roderick, 126 F.3d 1189 (9th Cir.1997), cert. denied, 522 U.S. 11 (<HOLDING>); see also Palma v. Atlantic County, 53 
 Holding statements: (A) holding that disputed issues of fact as to whether officer who allegedly gave false testimony before a grand jury could be considered a complaining witness prevented summary judgment (B) recognizing that absolute immunity is immunity from charges of either constitutional or statutory violations (C) holding that while a witness and prosecutor were protected by absolute immunity for their participation in judicial proceedings they were not entitled to absolute immunity on a  1983 claim that they conspired to present false testimony (D) holding that absolute immunity does not extend to a complaining witness who initiated a baseless prosecution by giving false testimony at either a grand jury proceeding or preliminary hearing (E) holding that a prosecutor accused of knowingly presenting false testimony at trial is protected by absolute immunity
Example Output:
holding that disputed issues of fact as to whether officer who allegedly gave false testimony before a grand jury could be considered a complaining witness prevented summary judgment