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.

Input: Consider 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

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

Input: Consider Input: Supreme Court rejected Cook's claim of error on direct appeal, finding that the prosecutor's comments were not directed at Cook's decision not to testify, and that the comment about the videotape was invited by Cook's cross-examination and argument. Cook, 821 P.2d at 741-43. The district court agreed that the comments were either comments on the state of the evidence or invited by Cook's arguments and cross-examination. In addition, the district court found that, if there was error, it was harmless under Brecht v. Abrahamson, 507 U.S. 619, 631, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993). Comment on the refusal to testify at trial violates a defendant's Fifth Amendment right against self-incrimination. See Griffin v. California, 380 U.S. 609, 615, 85 S.Ct. 1229, 14 L.Ed.2d 106 (1965) (<HOLDING>). Also, a prosecutor's comment on a defendant's
Holding statements: (A) recognizing that the fifth amendment forbids comment by the prosecution on a defendants failure to testify (B) holding that it is improper for prosecutor to comment on accuseds postarrest silence (C) holding fifth amendment prohibits comment on accuseds silence during police custodial interrogation (D) holding fifth amendment prohibits comment on accuseds testimonial silence (E) holding that the fifth amendment forbids either comment by the prosecution on the accuseds silence or instructions by the court that such silence is evidence of guilt

Output: recognizing that the fifth amendment forbids comment by the prosecution on a defendants failure to testify

Input: Consider Input: months). Subtracting the hypothetical chapter 13 expenses of $2,910 from the projected disposable income results in projected income available for distribution of $23,946. Comparing this amount with the debtor's present unsecured debt of $24,827, the debtor could repay approximately 96% of his debt within 36 months. 4 . It has been held, however, that the funds already in the qualified retirement account are not "disposable income" within the meaning of 1325(b). See In re Solomon, 67 F.3d 1128 (4th Cir.1995); In re Stones, 157 B.R. 669 (Bankr.S.D.Cal.1993). 5 . The cases upon which they rely, however, do not adopt a per se rule, but rather appear to address the necessity of the claimed expenses on a case per case basis. See, e.g., In re Festner, 54 B.R. 532, 533 (Bankr.E.D.N.C. 1985) (<HOLDING>); In re Fountain, 142 B.R. 135, 136-37 (Bankr.
Holding statements: (A) holding that debtors additional retirement fund was not reasonably necessary (B) holding that former husbands highway patrol retirement fund could be taken into account in dispersing marital property even though the fund was a substitute for social security (C) holding liability could not be transferred to the fund where the certificate of insurance was not signed (D) holding that a debtors inherited ira could not be exempt under a wisconsin statute because the source of the fund was immediately payable regardless of debtors age or retirement status (E) holding that an additional remedy does not constitute an additional requirement
Output: holding that former husbands highway patrol retirement fund could be taken into account in dispersing marital property even though the fund was a substitute for social security