In a recent lawsuit, captioned Maurice v. Lynsey Plasco-Flaxman and Joel Plasco, 18-cv-08841 (S.D.N.Y. Sept. 26, 2018), plaintiff, a nanny, accuses her new employers of race discrimination. The basis of her suit is a text message she received from defendant Lynsey – stating “NOOOOOOOOOOO ANOTHER BLACK PERSON” – that was apparently meant for her husband. After realizing her mistake, the Complaint alleges, Ms. Plasco-Flaxman “stated that she was uncomfortable and needed to terminate Plaintiff.” It further alleges that defendant said that her “outgoing nanny was also African-American and did not do her job properly” and that she was “expecting a Filipino nanny.” She seeks recovery under the Civil Right Act of 1866, codified at 42 U.S.C. 1981.