Following the Second Circuit's approach in Duplan, the Court will construe the § 1981 claims as causes of action brought under § 1983 and discuss whether the claims can survive pursuant to § 1983 caselaw. See Duplan v. City of New York, 888 F.3d 612, 621 (2d Cir. 2018) (discussing whether the § 1981 claims, although not plead pursuant to § 1983, were sufficiently alleged under § 1983 caselaw); see Gladwin v. Pozzi, 403 F. App'x 603, 605 (2d Cir. 2010); Lawtone-Bowles v. City of New York, No. 17-CV-8024 (AJN), 2019 WL 652593, at *6 (S.D.N.Y. Feb. 15, 2019); Healy v. Bd. of Educ. Ret. Sys. of City of New York, No. 17-CV-04016, 2019 WL 1243791, at *4 (E.D.N.Y. Mar. 18, 2019); Westbrook v. City Univ. of New York, 591 F. Supp. 2d 207, 223 (E.D.N.Y. 2008); see also Johnson v. City of Shelby, Miss., 135 S. Ct. 346, 347 (2014) (per curiam) ("plaintiffs seeking damages for violations of constitutional rights" do not need "to invoke § 1983 expressly in order to state a claim."). Throughout the remainder of this Opinion & Order, the Court will therefore refer to these claims as "cause[s] of action" brought pursuant to § 1983.