Q: 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.
when he injured a woman by accidentally hitting her with a golf cart. We agree with the district court that St. Paul Travelers, Inc., (St. Paul), the insurer, owed a duty to defend Scher from the time the Red Cross tendered Scher’s defense to St. Paul. See Montrose Chem. Corp. of California v. Super. Ct., 6 Cal.4th 287, 24 Cal.Rptr.2d 467, 861 P.2d 1153, 1160 (1993) (explaining that the duty to defend arises if there is potential liability). Indeed, St. Paul concedes this point on appeal. However, the district court erred in interpreting the terms of the St. Paul policy to exclude from the definition of “covered person,” volunteers who were not acting at the express direction of Kraft. See Bank of the West v. Super. Ct., 2 Cal.4th 1254, 1264-65, 10 Cal.Rptr.2d 538, 833 P.2d 545 (1992) (<HOLDING>) (citations omitted). As a result, St. Paul was 
 Holding statements: (A) holding that we must give the words in statutes their plain and ordinary meaning (B) holding that statutory words must be given their ordinary contemporary meaning (C) holding that an erisa insurance policy is governed by a uniform body of federal common law which requires policy language to be interpreted in an ordinary and popular sense as would a person of average intelligence and experience (D) holding that policy terms must be read in their ordinary and popular sense (E) holding that we are to read the statutory language in its ordinary and natural sense and if doubts remain resolve them in the light not only of the policy intended to be served by the enactment but as well by all other available aids to construction and looking to supplemental legislation and the scheme and structure of the legislation
A:
holding that we must give the words in statutes their plain and ordinary meaning