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 Input:
court is without power to extend that authority beyond the scope granted by the statute, and no District of Columbia court has ever found service upon such an unauthorized official to be valid against a foreign corporation. Accordingly, we conclude that service upon the Director was ineffective to bring Am-eritrade within the jurisdiction of the district court. Finally, Gorman urges that it would be unfair if a foreign corporation, lawfully subject to the jurisdiction of the District of Columbia because it does business here, could evade that jurisdiction by keeping its agents out of the District and hence beyond the range of effective service of process. If such a loophole does exist, the legislature can, of course, remove it by amending § 13-384 to provide an alternative method 1) (<HOLDING>); Oriental Trading Co. v. Firetti, 236 F.3d 
 Holding statements: (A) holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction (B) holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort (C) holding that the defendant companys action in sending a representative to ohio to negotiate a resolution of a prior dispute did not confer personal jurisdiction (D) holding that foreseeability of causing injury in forum state is not sufficient for specific personal jurisdiction (E) holding that phone and facsimile communications to the forum purchase orders and payments sent to the forum a choice of law clause within the contract regarding the forum state and delivery of the product within the forum state were not enough to satisfy minimum contacts

Ex Output:
holding that purposeful availment may exist when a defendant makes phone calls and sends facsimiles into the forum state and such communications form the bases for the action of an intentional tort


Ex Input:
good or replace the loss caused by the wrong or injury * * Black’s Law Dictionary 390 (6th ed. 1990) (emphasis added); see also Restatement (Second) Torts § 903 (defining compensatory damages as “damages awarded to a person as compensation, indemnity or restitution for harm sustained by him”); Webster’s Third New Int’l Dictionary 463 (3rd ed. 1961) (defining compensatory damages as “damages awarded to make good or compensate for an injury sus tained — distinguished from punitive damages ”). When civil rights plaintiffs seek “damages for violations of constitutional rights, the level of damages is ordinarily determined according to principles derived from the common law of torts.” Memphis Community School Dist. v. Stachura, 477 U.S. 299, 306, 106 S.Ct. 2537, 2542, 91 L.Ed.2d 249 (1986) (<HOLDING>). “Punitive damages aside, damages in tort 
 Holding statements: (A) holding that punitive damages are available in an intentional discrimination action even if the jury does not assess compensatory damages (B) holding that punitive damages which are based on the same underlying action justifying nondischargeability of compensatory damages are likewise nondischargeable (C) holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated (D) holding that damages based on the abstract value of constitutional rights are not a permissible element of compensatory damages in action under civil rights act of 1871 (E) holding that damages based on the abstract value or importance of constitutional rights are not a permissible element of compensatory damages in such cases

Ex Output:
holding that punitive damages are available in an intentional discrimination action even if the jury does not assess compensatory damages


Ex Input:
Clause even when a criminal conviction arises out of the same incident. Halper, supra, 490 U.S. at 448-49, 109 S.Ct. at 1902, 104 L.Ed.2d at 502. Furthermore, defendant’s conviction for aggravated assault did not violate the Double Jeopardy Clause because the domestic violence proceeding was between the victim and defendant and did not involve the State. Halper states that “[t]he protections of the Double Jeopardy Clause are not triggered by litigation between private parties.” Id. at 451, 109 S.Ct. at 1903, 104 L.Ed.2d at 503. Since the domestic violence action in this case did not involve the State, the Double Jeopardy Clause was not implicated. Ibid., see also Browning-Ferns Indus., Inc. v. Kelco Disposal, Inc., 492 U.S. 257, 260, 109 S.Ct. 2909, 2912, 106 L.Ed.2d 219, 228 (1989) (<HOLDING>). Consequently, the trial court properly denied 
 Holding statements: (A) holding that forfeitures may violate the eighth amendment excessive fines clause (B) holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable (C) holding that punitive damages are not fines (D) holding that excessive fines clause of eighth amendment does not apply to punitive damage awards between private parties (E) holding that excessive fines clause does not apply to civiljury award of punitive fines

Ex Output:

holding that forfeitures may violate the eighth amendment excessive fines clause