What causes of action can a plaintiff bring in a common law cause of action for emotional distress and wrongful discharge?

It is equally settled that the common law of this state provides any number of remedial theories to compensate for injuries "relating to discrimination" ( 12993, subd. (a) ). Brown v. Superior Court (1984) 37 Cal.3d 477, 208 Cal.Rptr. 724, 691 P.2d 272 is illustrative. There the plaintiff filed a civil suit alleging a statutory cause of action for discharge on grounds of race and common law causes of action for emotional distress and wrongful discharge. Each of the three claims was based on the same factual allegations regarding liability and damages. "[E]mployment discrimination cases," we observed, "by their very nature, involve several causes of action arising from the same set of facts. A responsible attorney handling an employment discrimination case must plead a variety of statutory, tort and contract causes of action in order to fully protect the interests of his or her client. [Fn. omitted.]" (Id. at p. 486, 208 Cal.Rptr. 724, 691 P.2d 272, emphasis added.) Although the common law theories do not per se "relate to discrimination," they are nonetheless a standard part of a plaintiff's arsenal in a discrimination case. (See generally Montgomery, Sexual Harassment in the Workplace:

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