example, has refused to apply principles of res judicata to bar State discrimination claims after the plaintiff lost federal discrimination claims. Andujar v. National Property & Casualty Underwriters, 659 So. 2d 1214 (Fla. 4th DCA 1995) (adverse judgment against plaintiff in federal court for federal

discrimination laws). Here, although some of the elements for some of the claims may be similar, they are sufficiently different that application of Andujar would preclude res judicata. To determine whether a case is parallel, courts have looked to whether the same issues are being litigated. Calvert Fi

litigation about statute of limitations issues. Courts have commonly allowed Rule 15 amendment that relate back in similar circumstances. See, e.g., Andujar v. Rogowski, 113 F.R.D. 151 (S.D.N.Y. 1986) (allowing addition of new plaintiffs even after a statute of limitations had expired). We write to you

iscrimination laws). Here, although some of the elements for some of the claims may be similar, they are sufficiently different that application of Andujar would preclude res judicata. To determine whether a case is parallel, courts have looked to whether the same issues are being litigated. Calvert Fi