With no explanation, chose the best option from "A", "B", "C" or "D". working conditions; a racial discrimination claim alleging wrongful termination based on racial animus; and a claim alleging a racially hostile work environment. (See Doc. 1). “Because the legal standards governing each of these categories of claims are the same, it is unnecessary to evaluate separately the Title VII ... and the § 1981 causes of action.” Pears v. Mobile County, 645 F.Supp.2d 1062, 1089 (S.D.Ala.2009). Title VII prohibits an employer from discriminating against a person based on race. 42 U.S.C. § 2000e-2(a)(l). Likewise, 42 U.S.C. § 1981 prohibits intentional race discrimination in the making and enforcement of public and private contracts, including employment contracts. See, e.g., Johnson v. Railway Express Agency, 421 U.S. 454, 95 S.Ct. 1716, 44 L.Ed.2d 295 (1975) (<HOLDING>). Section 1981 liability must be founded on

A: holding with little discussion that section 1981 applies to private racial discrimination
B: holding that  1981 protects against discrimination based on ancestry
C: holding that title vii proscribe racial discrimination in private employment against whites on the same terms as racial discrimination against nonwhites
D: holding unequivocally that  1981 protects against racial discrimination in private employment
D.