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:
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:
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

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

Ex Input:
dock. As discussed above, the Declaration does not unambiguously create a dock easement on Parcel A and it is not an undisputed fact that the Davids took Parcel A subject to the Declaration or the dock easement. And it follows that if the Davids took Parcel A unrestricted by the Declaration, the property is also not sub" ject to the amendments that were later unilaterally executed by Ippolite, who no longer owned Parcel A. See Endruschat v. Am. Title Ins. Co., 377 So.2d 738, 741 (Fla. 4th DCA 1979) ("[AJuthority throughout the country, with which we agree, would indicate that a developer cannot seek to encumber property with restrictions [a]f-tfer he has sold it."). Furthermore, the terms of the Declaration provide that the Declaration "may be mo 1144, 1145-46 (Fla. 4th DCA 2009) (<HOLDING>). Reversed and remanded for proceedings
Holding statements: (A) holding that an exclusionary clause in an insurance contract that lends itself to different interpretations is ambiguous and must be construed in a manner most favorably to the insured (B) holding that when a contract is ambiguous and the parties suggest different interpretations summary judgment is inappropriate because an issue of fact exists (C) holding that where each side ascribes a different meaning to what the sides claim is the unambiguous language in a contract the contract is ambiguous and summary judgment is improper (D) holding that a contract is ambiguous if a reasonable person would find it susceptible to different or inconsistent interpretations (E) holding that summary judgment is appropriate when no issue of material fact exists and the court is reviewing administrative record for sufficiency of evidence

Ex Output:
holding that an exclusionary clause in an insurance contract that lends itself to different interpretations is ambiguous and must be construed in a manner most favorably to the insured