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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Example Input: a housing development. Streckfus, 504 N.E.2d at 274. She was an at-will employee but had an employment agreement with the development's management company. Id. at 274-275. Her employment agreement referenced a management contract between the development and the management company, and the management contract provided procedures by which the management company could terminate a Resident Manager. Id. Our supreme court held that "as a matter of law, the Employment Agreement did not contain any job security provision which altered the employment at will relationship. ... Id. at 276. The Trails fail to demonstrate that Eddie states a claim upon which relief could be granted based upon the Club's Articles of Incorporation or the Club's standard practices. See also Orr, 689 N.E.2d at 719-720 (<HOLDING>). Even viewing the Trails' breach of contract 
 Holding statements: (A) holding that an arbitration agreement in an employee handbook was illusory where the employer expressly reserved a right to unilaterally rescind any provisions of the handbook (B) holding that employee handbook did not give rise to implied contract where it stated that it was not a contract and that employment was terminable at will (C) holding employee handbook or employers printed statement of policy are promises in implied offer of unilateral contract which an employee can accept by beginning or continuing to work for employer (D) holding that employee may claim contract created based on employer promise of severance pay to employee (E) holding that an employee handbook did not constitute a valid unilateral contract between the employee and employer in the absence of adequate independent consideration
Example Output: (E)

Example Input: 563 U.S. 421, 438, 131 S.Ct. 1866, 179 L.Ed.2d 843 (2011). Nonetheless, the District Court and the Plan have cited to the language in the Summary Plan Description (“SPD”) as the language of the Plan. We, too, adopt this approach. See US Airways, Inc. v. McCutchen, 569 U.S. 88, 133 S.Ct. 1537, 1543 n.1, 185 L.Ed.2d 654 (2013) ("Because everyone in this case has treated the language from the summary description as though it came from the plan, we do so as well.”). Moreover, insofar as McLaughlin and J.J.M. now contend that the SPD was not "designated a plan document” and so cannot control here, McLaughlin Reply Br. 1, we deem this argument forfeited because it is raised solely in the reply brief. See Laborers' Int'l Union of N. Am. v. Foster Wheeler Corp., 26 F.3d 375, 398 (3d Cir. 1994) (<HOLDING>). 4 . We have considered McLaughlin's and 
 Holding statements: (A) holding an argument not raised in opening brief is waived (B) holding that a party waives an argument that it raises in the background section of its brief but not in the argument section (C) holding argument waived for failure to raise it in opening brief (D) holding that argument not raised in opening brief is waived (E) holding that an argument is not preserved unless a party raises it in its opening brief
Example Output: (E)

Example Input: for the employee.” Id. at 1011. “However, employers can effectively disclaim any implied contractual obligation arising from such provisions.” Id. “‘The legal effect of such a disclaimer is, in the first instance, a question for the court to decide.’ ” Id. (quoting Smith v. Union Labor Life Ins. Co., 620 A.2d 265, 269 (D.C.1993)). A mere statement that the employee handbook is not a contract does not necessarily settle the matter. See Strass, 744 A.2d at 1012-14. Rather, for provisions relating to employee termination to be “unenforceable at law,” our cases have held that the employee handbook “must contain language clearly reserving the employer’s right to terminate at will.” Sisco v. GSA Nat’l Capital Fed. Credit Union, 689 A.2d 52, 55 (D.C.1997); See, e.g., Smith, 620 A.2d at 269 (<HOLDING>); see also Kerrigan v. Britches of Georgetowm, 
 Holding statements: (A) recognizing that wrongful or malicious interference with atwill employment contract may give rise to a tortious interference claim the fact that the employment is at the will of the employer and the employee does not make it one at the will of third parties (B) holding that employee handbook did not give rise to implied contract where it stated that it was not a contract and that employment was terminable at will (C) holding that an employment contract of an indefinite duration is terminable at will (D) holding that a contract of an indefinite duration is terminable at will (E) holding that language in employee handbook stating that it was not to be considered as creating terms and conditions of an employment contract and that the employment relationship was employment atwill  was sufficiently explicit to preclude the creation of implied contractual obligations as a matter of law
Example Output:
(B)