her first.  Like her first complaint, it asserted causes of action under 42 U.S.C. §§ 1981 and 1983 and Title VII.  In addition, the second complaint, like the first, alleged that Mrs. Walton had been harassed, discharged, and denied equal treatment in pay, promotions, and educational opportunities because of her race and sex.  However, Mrs. Walton's second complaint did differ from her first in three respects: it was not brought as a class action; it contained a general demand for a trial by jury; and this second complaint, unlike the first, alleged that Mrs. Walton had suffered "emotional and mental injury" as a result of the defendant's action.  Consequently the second complaint apparently sought compensatory damages,3 while the first complaint sought only punitive damages.


8
Onthe job; and that Eaton discriminated against her with respect to pay, promotions, and opportunities to obtain educational benefits.  Moreover, the addition in this case of the allegation that Mrs. Walton suffered "mental and emotional injury" is analogous to the amendment in Lanza which alleged for the first time that the defendants had acted willfully.  Both "amendments" pleaded facts which had not been alleged in the previous complaints, but neither raised a "new issue," since they did not change the "basic issue" in the case or the "general area of dispute."


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In sum, under the sound reasoning of Lanza and the other authorities treating with this point, it is obvious that no "new issue" was added by Mrs. Walton's second complaint7a and that therefore her first complaint