How have courts considered whether discrimination claims are interrelated?

Odima v. Westin Tucson Hotel (9th Cir. 1995) 53 F.3d 1484, also illustrates the need to review the trial evidence in determining if claims are interrelated. In Odima, the plaintiff prevailed on his claims that his employer discriminated against him on the basis of race and nationality, but he was unsuccessful on his claims for wrongful termination, constructive discharge, retaliation, and intentional infliction of emotional distress. The court held that plaintiff's claims were interrelated. (Id. at 1499.) The court stated that the district court "issued a lengthy memorandum opinion," set forth "detailed findings of fact" and summarized the evidence regarding plaintiff's discrimination claims. (Id. at pp. 1488-1490, 1492.) The court in Odima also set forth in detail the facts of plaintiffs claims. (Id. at pp. 1489-1491.)

In holding that all of plaintiff's claims were interrelated, the court found that at trial the plaintiff was required to present virtually the same evidence for all of his claims. (Odima v. Westin Tucson Hotel, supra, 53 F.3d at p. 1499.) The court stated that "[t]o prove the discrimination claims pursuant to Title VII and section 1981, [the plaintiff] had

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