Cramlett’s lawyer, Thomas Intili, told NBC News his client “lives in an all-white community in eastern Ohio. She did not encounter any African-American people until she entered college. Not all her friends and family members are racially sensitive.”

As an example of the difficulties the family faces, the suit cited hair care for the toddler.

“Getting a young daughter’s hair cut is not particularly stressful for most mothers, but to Jennifer it is not a routine matter, because Payton has hair typical of an African American girl,” the suit says. “To get a decent cut, Jennifer must travel to a black neighborhood, far from where she lives, where she is obviously different in appearance, and not overtly welcome.”