instruction:
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.
question:
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
answer:
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


question:
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
answer:
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


question:
in his person or property or deprived of any right or privilege of a citizen of the United States” as a result of the officers’ alleged conspiracy. Farber v. City of Paterson, 440 F.3d 131, 134 (3d Cir.2006). As discussed previously, Mills suffered no injury to his constitutional rights. See Part II.A-B, supra. Accordingly, the District Court did not err in granting summary judgment on Mills’s claims under § 1985(3). D. Finally, Mills seeks reversal of the District Court’s grant of summary judgment on his several pendent state law claims. Because Mills’s arrest was supported by probable cause, however, his claims for false arrest, false imprisonment, and malicious prosecution cannot survive under Pennsylvania law. See Renk v. City of Pittsburgh, 537 Pa. 68, 641 A.2d 289, 293 (1994) (<HOLDING>); Lippay v. Christos, 996 F.2d 1490, 1502 (3d 
 Holding statements: (A) recognizing that an arrest based on probable cause cannot be the basis of a claim for false arrestimprisonment (B) holding that probable cause is a complete defense to an action for false arrest (C) holding that a determination of probable cause does not bar a state law malicious prosecution claim where the claim is based on the police officers supplying false information to establish probable cause (D) holding that there is no  1983 cause of action for false arrest unless the arresting officer lacked probable cause (E) holding that the existence of probable cause is a complete defense to a  1983 claim alleging false arrest
answer:

holding that probable cause is a complete defense to an action for false arrest