Read the following excerpt from a US court opinion:
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However, the cases plaintiffs point us to do not support their argument on appeal. First, in most of these cases, the Circuit Courts were focused on the effect of Lingle on their Takings Clause precedent, not their substantive due process case law. See, e.g., Rose Acre Farms, Inc. v. United States, 559 F.3d 1260, 1277-82 (Fed. Cir.2009) (discussing how the Agins inquiry is now obsolete after Lingle and examining Lingle’s effect on regulatory takings cases). Second, the Circuit Courts that did find Lingle affected their substantive due process jurisprudence had earlier precedent holding that all property rights-based substantive due process claims were preempted or supplanted by the Takings Clause. See, e.g., Crown Point Dev., Inc. v. City of Sun Valley, 506 F.3d 851, 852 (9th Cir.2007) ; see also A Helping Hand, LLC v. Balt. Cnty.,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that a foreign citizen with no substantial connections to the us has no claim under the fifth amendments takings clause
B. recognizing  1983 substantive due process claim
C. holding that prior circuit precedent that the fifth amendments takings clause subsumes or preempts substantive due process claims was undermined by lingle
D. holding that when a prisoners deliberate indifference claim is covered by the eighth amendment the substantive due process claims are duplicative and thus the substantive due process claims should be dismissed
E. holding municipalities  are not persons within the meaning of the due process clause of the fifth or fourteenth amendments
Reply with [A, B, C, D, E] only.