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: pain and suffering, demonstrated his reliance on a prohibited tort theory); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242-43 (1988) (declining to consider an intentional infliction of emotional distress action, in which the plaintiff sought damages for "anguish, shock, nervousness, and depression," because the abolition of claims for alienation of affections was intended to preclude these allegations); see also Wilson v. Still, 819 P.2d 714, 716 (Okla.1991) (finding a suit for intentional infliction of emotional distress was barred because the plaintiff basically sued the defendant for "wil-fully taking away her husband" and stating the legislature immunized that conduct from tort liability). But see Erickson v. Christenson, 99 Or.App. 104, 781 P.2d 383, 385-86 (1989) (<HOLDING>), appeal dismissed, 311 Or. 266, 817 P.2d 758
Holding statements: (A) holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute (B) holding a plaintiff could proceed on a claim alleging intentional infliction of emotional distress because the alleged losses were different from those for seduction but also stating plaintiffs previously suing for seduction could recover for damage to character and reputation as well as for mental anguish and pecuniary losses (C) recognizing validity of cause of action for intentional infliction of emotional distress (D) holding that police officers were immune from liability for damages resulting from alleged intentional infliction of emotional distress (E) recognizing the tort of intentional infliction of emotional distress
Example Output: holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute

Example Input: an intention that suits for pension benefits by disappointed applicants are equitable."), cert. denied, 449 U.S. 1112, 101 S.Ct. 922, 66 L.Ed.2d 841 (1981); see also Sullivan v. LTV Aerospace and Defense Co., 82 F.3d 1251, 1258-59 (2d Cir.1996); Berry v. Ciba-Geigy Corp., 761 F.2d 1003, 1007 (4th Cir.985); Turner v. CF & I Steel Corp., 770 F.2d 43, 47 (3d Cir.1985), cert. denied, 474 U.S. 1058, 106 S.Ct. 800, 88 L.Ed.2d 776 (1986); In re Vorpahl, 695 F,2d 318, 321-22 (8th Cir.1982); Calamia v. Spivey, 632 F.2d 1235, 1237 (5th Cir. Unit A 1980). Some district courts have suggested that Firestone Tire & Rubber v. Bruch, 489 U.S. 101, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989), calls these holdings into doubt. See, e.g., Hulcher v. United Behavioral Sys., 919 F.Supp. 879, 885 (E.D.Va.1995) (<HOLDING>); Vaughn v. Owen Steel Co., 871 F.Supp. 247,
Holding statements: (A) holding that 1132a1b affords the plaintiff adequate relief for her benefits claim and a cause of action under 1132a3 is thus not appropriate (B) holding plaintiff had no claim under 1132a3 because his grievance that benefits were denied is specifically addressed in 1132a1b (C) holding that plaintiff in erisa action was entitled to restitution under similar circumstances (D) holding that claims for misrepresentation under texas insurance code were preempted because the plaintiffs sought to recover benefits under an erisa plan (E) holding that action to recover erisa benefits under the subject plan are legal in nature and that plaintiff is constitutionally entitled to trial by jury on any claim raised under 1132a1b
Example Output: holding that 1132a1b affords the plaintiff adequate relief for her benefits claim and a cause of action under 1132a3 is thus not appropriate

Example Input: for the purposes of res judicata."); Heade v. Washington Metro. Area Transit Auth., No. 09-02460, 2010 WL 938462, at *2 n. 2 (D.D.C. Mar. 12, 2010) ("Plaintiff's contention that the arbitration's findings do not bar her claim because she was not a party to that proceeding is also without merit .... [since] she was in privity with her union."); see also Hitchens v. County of Montgomery, 98 Fed.Appx. 106, 114 (3d Cir.2004) ("[C]ourts have held union members to be in privity with the union and have held-that a decision against a union can bind union members in a subsequent action." (citing Handley v. Phillips, 715 F.Supp. 657, 666-67 (M.D.Pa.1989); Stokes v. Bd. of Tr. of Temple Univ., 683 F.Supp. 498, 502 (E.D.Pa.1988)); Monahan v. Dep't. of Corr., 214 F.3d 275, 285-86 (2d Cir.2000) (<HOLDING>); Meza v. Gen. Battery Corp., 908 F.2d 1262,
Holding statements: (A) recognizing that union members interests are adequately represented by the union (B) recognizing that the involvement of supervisory union members in union affairs conflicts with the need to assure the complete devotion of union negotiating teams to employee interests (C) holding that a rico action by union members was properly dismissed where any financial improprieties occurred with union funds and directly injured solely the union (D) holding union members state law claims for defamation against union preempted (E) recognizing union members vital concern in preserving jobs for union members
Example Output:
recognizing that the involvement of supervisory union members in union affairs conflicts with the need to assure the complete devotion of union negotiating teams to employee interests