With no explanation, chose the best option from "A", "B", "C" or "D". of contract claims, for purposes of statutes of limitations. Id. at 1206. However, neither the Tenth Circuit nor the District Courts for the District of Kansas has characterized ERISA § 510 claims under Kansas law. The circuit courts that have considered claims similar to Myers’ have almost unanimously concluded that the most analogous state-law cause of action under § 510 is “wrongful termination” or “retaliatory discharge,” catchall descriptions of state-law causes of action encompassing an employee’s claim that he was discharged in violation of public policy. See Teumer v. General Motors, 34 F.3d 542, 549-50 (7th Cir.1994) (retaliatory discharge encompassing interference “with the exercise of favored rights.”); Burrey v. Pacific Gas & Elec. Co., 159 F.3d 388, 397 (9th Cir.1998) (<HOLDING>); Byrd v. MacPapers, Inc., 961 F.2d 157, 159

A: recognizing tort of wrongful discharge in violation of public policy
B: holding that the oneyear statute of limitations for a tort action for wrongful termination in violation of public policy applied to the plaintiffs erisa  510 claim
C: holding a claim for wrongful termination in violation of public policy is not available where the employee has an existing statutory remedy
D: recognizing common law tort claim for wrongful discharge in violation of ohio public policy based upon statutory and judicial sources
B.