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.

States Supreme Court and the Court of Appeals for the Second Circuit have previously rejected this analysis on multiple occasions. See Harris Trust & Sav. Bank v. Salomon Smith Barney, Inc., 530 U.S. 238, 247, 120 S.Ct. 2180, 147 L.Ed.2d 187 (2000) (finding that ERISA Section 502(a)(3) strictly limits the "universe of plaintiffs who may bring certain civil actions.") (emphasis in original); Franchise Tax Bd. v. Constr. Laborers Vacation Trust for S. Cal., 463 U.S. 1, 27, 103 S.Ct. 2841, 77 L.Ed.2d 420 (1983) ("ERISA carefully enumerates the parties entitled to seek relief under [ 502(a)(3) ]; it does not provide anyone other than participants, beneficiaries, or fiduciaries with an express cause of action.... "); Nechis v. Oxford Health Plans, Inc., 421 F.3d 96, 100 (2d Cir.2005) (<HOLDING>); Chemung Canal Trust Co. v. Sovran Bank/Md.,
Holding statements: (A) holding that a plaintiff seeking individual relief under erisa 502a3 under a breach of fiduciary duty theory did not have a cause of action when the alleged breach of fiduciary duty was a failure to distribute benefits in accordance with the plan (B) holding that collective bargaining agent representing employees had representational standing and therefore could bring an action under section 502 of erisa (C) holding that a lawyer who is fully aware of his clients obligation under an erisa plan to honor the subrogation interest of his employer may be held liable under section 502a3 of erisa (D) holding that claims for equitable relief under 502a3 are only available when a plaintiff has no other relief under erisa (E) holding that only members of the enumerated classes have standing to bring a civil action under erisa section 502a3
holding that a plaintiff seeking individual relief under erisa 502a3 under a breach of fiduciary duty theory did not have a cause of action when the alleged breach of fiduciary duty was a failure to distribute benefits in accordance with the plan