With no explanation, chose the best option from "A", "B", "C" or "D". to the NLRB, the state’s jurisdiction is preempted. Id. at 197, 201, 98 S.Ct. 1745; see also Belknap, 463 U.S. at 511, 103 S.Ct. 3172 (applying primary jurisdiction test to state regulation of arguably prohibited conduct). As to whether the picketing was arguably protected by the NLRA, the Court went beyond the primary jurisdiction test to address additional federal supremacy concerns — whether, despite the lack of identi-cality between issues the state court and NLRB might consider, preemption was warranted to protect against the risk of “misinterpretation of [the NLRA] and the consequent prohibition of protected conduct.” Sears, 436 U.S. at 203, 98 S.Ct. 1745. We employed this “primary jurisdiction plus” approach in Radcliffe v. Rainbow Const. Co., 254 F.3d 772, 786 (9th Cir.2001) (<HOLDING>). a. Primary Jurisdiction The parties do not

A: holding that false arrest and false imprisonment claim were not duplicative
B: holding that false arrest is one means of committing false imprisonment
C: holding union members state law claims for defamation against union preempted
D: holding that state jurisdiction over claims by union members against employer for false arrest false imprisonment and malicious prosecution were not preempted under garmon
D.