Statute Annotations › Federal › 42 U.S.C. § 1983

42 U.S.C. § 1983

Civil action for deprivation of rights: the cases that interpreted this section

Jurisdiction
Federal
Case notes
71,725
Cited in passing
92,787
Citing cases indexed
283,166
Case dates
1955–2021
Screened through
2021-01-26
Checked for later law changes
2026-10-17
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

164,512 citing cases reviewed of 283,166 in the citation index: 71,725 interpreted the section (annotated below), 92,787 cited it only in passing. Cases filed after 2021-01-26 may not have been reviewed yet.

Have a situation under 42 U.S.C. § 1983?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Supervisory liability

Section 1983 does not impose vicarious liability on supervisors; a supervisor may be liable for personal involvement in a constitutional violation or a sufficient causal connection between the supervisor’s conduct and the violation.

Marquez v. Quarterman · filed 2009-08-12

Under 42 U.S.C. § 1983, supervisory officials are not liable for subordinates’ actions on any vicarious liability theory. A supervisor may be held liable if either of the following exists: (1) his personal involvement in the constitutional deprivation, or (2) sufficient causal connection between the supervisor’s wrongful conduct and the constitutional violations.
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Section 1983 requires a causal link between a supervisor’s own conduct or inaction and a subordinate’s violation; supervisory status alone does not create liability.

Rodríguez-Vázquez v. Cintrón-Rodríguez · filed 2001-08-23

Indeed, since there is no respondeat superior liability under Section 1983, the basis for imposing Section 1983 liability is the concept of causation and fault by a particular defendant.
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Section 1983 holds a supervisor personally liable only if the supervisor caused the specific constitutional violation, which requires knowledge of and acquiescence in the challenged conduct.

Lessley v. CITY OF MADISON, IND. · filed 2009-08-21

While a municipality may be liable because of its acts or omissions, a supervisor must have personally caused the specific constitutional violation. This requires, at least, knowledge of the specific conduct challenged and acquiescence to the conduct.
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Section 1983 does not impose liability on a supervisor solely because of that role; the plaintiff must show personal involvement or a sufficient causal connection to the constitutional violation.

Gray v. Hernandez · filed 2009-08-27

The R & R notes respondeat superior liability does not exist under § 1983. ... The court therefore agrees with the findings of the R & R. Defendant Hernandez’s motion to dismiss is GRANTED.
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Section 1983 supervisory liability for failure to train requires a complete failure to train or training that is reckless or grossly negligent.

Smith v. Lejeune · filed 2002-05-17

As stated above, only a complete failure to train or training that is reckless or grossly negligent will constitute the deliberate indifference required to disqualify a state actor from qualified immunity from suit.
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Section 1983 does not impose liability on a supervisor who failed to intervene in alleged misconduct but did not directly participate in it.

Lynch-Bey v. Bolden · filed 2002-08-13

Lynch-Bey did not allege that Bolden directly participated in the alleged misconduct. ... Thus, his allegations that Bolden did not intervene on his behalf are insufficient to state a § 1983 claim.
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Section 1983 imposes liability on the official who causes a constitutional violation and does not impose liability solely because a defendant supervises the wrongdoer.

Sosa v. Lantz · filed 2009-09-02

In an action filed pursuant to 42 U.S.C. § 1983, liability is imposed only on the official causing a constitutional violation, and Plaintiff alleges no facts regarding Rell or McDonald.
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Section 1983 permits personal liability for a supervisor only when the supervisor personally participates in the constitutional violation or has the required causal connection to it.

American Federation of Labor-Congress of Industrial Organizations v. City of Miami · filed 2009-09-02

Instead, a supervisor is only personally liable under § 1983 when (i) he personally participates in the alleged constitutional violation, or (ii) there is a causal connection between the actions of the supervisor and the alleged constitutional violation. ... The necessary causal connection can be established by facts supporting an inference that a supervisor either directed the unlawful acts or knew that his subordinates were going to act unlawfully and failed to stop them from doing so.
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Section 1983 does not impose strict vicarious liability on supervisors for their subordinates’ actions, and supervisors may be liable based on their personal involvement in constitutional violations.

Al-Kidd v. Ashcroft · filed 2009-09-04

Neither a 42 U.S.C. § 1983 nor a Bivens action will hold a supervisor strictly vicariously liable for the actions of his subordinates under a theory of respondeat superior. ... Supervisors can be held liable for the actions of their subordinates (1) for setting in motion a series of acts by others, or knowingly refusing to terminate a series of acts by others, which they knew or reasonably should have known would cause others to inflict constitutional injury; (2) for culpable action or inaction in training, supervision, or control of subordinates; (3) for acquiescence in the constitutional deprivation by subordinates; or (4) for conduct that shows a "reckless or callous indifference to the rights of others." Larez v. City of Los Angeles, 946 F.2d 630, 646 (9th Cir.1991) (internal quotation marks omitted). Any one of these bases will suffice to establish the personal involvement of the defendant in the constitutional violation.
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Section 1983 does not impose supervisory liability through respondeat superior; liability must arise from the supervisor’s own acts or omissions.

Lopera v. Town of Coventry · filed 2009-09-09

Supervisory liability cannot be predicated on a respondeat superior theory, and instead must stem from the supervisor’s own acts or omissions.
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Section 1983 does not allow liability based solely on a supervisor’s position.

Escobar v. Reid · filed 2009-09-17

As the Magistrate Judge notes, claims under 42 U.S.C. § 1983, like those Plaintiff alleges in this case, do not allow a plaintiff to hold a defendant liable under a respondeat superior theory.
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A § 1983 claim against a supervisor in an individual capacity requires allegations of the supervisor’s personal involvement in the constitutional deprivation.

Rivera v. Fischer · filed 2009-09-18

A plaintiff asserting a § 1983 claim against a supervisory official in his individual capacity must allege that the supervisor was personally involved in the alleged constitutional deprivation.
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Section 1983 does not impose liability on a supervisor solely because subordinates allegedly violated a plaintiff’s constitutional rights.

Covell v. Arpaio · filed 2009-09-24

Because there is no respondeat superior liability under § 1983, a defendant’s position as the supervisor of persons who allegedly violated Plaintiffs constitutional rights does not impose liability.
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Section 1983 requires a supervisor’s personal involvement for individual liability; supervisory status alone is insufficient.

Eileen L. Kosloski, Administra v. Dunlap · filed 2009-09-24

However, “[b]ecause § 1983 liability cannot be imposed under a theory of respondeat superior, proof of personal involvement is required for a supervisor to incur personal liability.”
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Section 1983 requires a supervisor’s personal involvement in the alleged violation; merely receiving two letters from an inmate does not establish it.

Gonzalez v. Wright · filed 2009-09-30

Even if there had been a constitutional violation here, plaintiffs evidence falls short of showing Dr. Wright was personally involved in it. The mere receipt of two letters from an inmate is insufficient to show the requisite personal involvement for a section 1983 claim.
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Section 1983 requires each defendant’s personal involvement in the deprivation of constitutional rights; supervisors are not liable solely because of their position.

Cruz-Acevedo v. Toledo-Davila · filed 2009-09-30

Plaintiffs must show that each individual defendant was involved personally in the deprivation of constitutional rights because no respondeat superior liability exists under section 1983.
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Section 1983 does not make a supervisor liable for a subordinate's civil rights violation solely because of their supervisory relationship.

Doe Hm v. City of Creve Coeur, Mo. · filed 2009-09-30

This argument is directly contradicted by the above-cited cases holding that respondeat superior liability is not available in § 1983 actions.
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Section 1983 does not impose respondeat superior liability on supervisors and requires personal involvement or a sufficient causal connection to the constitutional violation.

Adams v. Banks · filed 2009-09-30

As a threshold matter, there is no respondeat superior liability on the part of supervisors. “To state a cause of action under § 1983, the plaintiff must allege facts reflecting the defendants’ participation in the alleged wrong, specifying the personal involvement of each defendant.”
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A supervisor may be liable under § 1983 for a subordinate’s unconstitutional acts if the supervisor personally participated or was causally connected to the constitutional deprivation.

Campbell v. Johnson · filed 2009-09-30

As a supervisory official, Sheriff Johnson is only liable under § 1983 for the unconstitutional acts of his subordinates if he personally participated in the allegedly unconstitutional conduct, or his actions were causally connected to the alleged constitutional deprivation.
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Section 1983 does not impose vicarious liability on supervisors; a supervisor must be personally involved in the constitutional deprivation or have a sufficient causal connection to it.

Leibowitz v. CITY OF MINEOLA, TEX. · filed 2009-10-02

Under 42 U.S.C. § 1983, supervisory officials are not liable for subordinates’ actions on any vicarious liability theory. A supervisor may only be held liable if either of the following exists: (1) he is personally involved in the constitutional deprivation, or (2) there is a sufficient causal connection between the supervisor’s wrongful conduct and the constitutional violations.
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Section 1983 permits supervisory liability when a complaint adequately alleges the supervisor’s substantial personal participation in the conduct at issue.

Masters v. Gilmore · filed 2009-10-05

In view of Mr. VanMeveren’s substantial personal participation with the investigation and prosecution of Mr. Masters as alleged in the Amended Complaint, I conclude that Mr. Masters has adequately pled the required elements of supervisory liability under § 1983.
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Section 1983 requires a plaintiff suing a supervisory official to allege facts showing that official’s personal involvement in the alleged constitutional violation.

Marrero v. Kirkpatrick · filed 2009-10-05

A plaintiff asserting a § 1983 claim against a supervisory official must allege facts showing that the defendant was personally involved in the alleged constitutional violation.
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Section 1983 does not impose liability on supervisors for their subordinates’ actions solely because of their supervisory roles; the plaintiff must allege the supervisors’ own involvement.

Delaney v. District of Columbia · filed 2009-10-06

The § 1983 claims against these officials fail because (1) there are no allegations that any of these Defendants was personally involved in any of the alleged violations of Plaintiffs’ constitutional rights and (2) they cannot be held liable under § 1983 for the actions of their subordinates on the basis of respondeat superior.
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Supervisory officials are liable under § 1983 only if they participate in the constitutional deprivation or implement an unconstitutional policy that causes the plaintiff’s injury.

Thompson v. Johnson · filed 2009-10-06

Officials acting in a supervisory role may only be held liable under § 1983 if they either (1) affirmatively participate in acts that cause a constitutional deprivation or (2) implement unconstitutional policies that causally result in the plaintiff’s injury.
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Section 1983 permits supervisory liability when a supervisor personally participates in unconstitutional conduct or has a causal connection to it.

Harper v. Lawrence County · filed 2009-10-07

Supervisory liability lies where the defendant personally participates in the unconstitutional conduct or there is a causal connection between such conduct and the defendant’s actions.
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Section 1983 requires a supervisor reviewing a prison grievance to have an opportunity to remedy an ongoing constitutional violation before the review can establish personal involvement.

Burton v. Lynch · filed 2009-10-13

A superintendent cannot “remedy” a violation of constitutional rights which has already ceased by ordering some change in prison conditions. ... Accordingly, Plaintiff has not alleged facts indicating that Defendant Connolly was personally involved in any alleged violation of his constitutional rights, and his claims against Defendant Connolly are therefore dismissed.
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Section 1983 does not impose liability on a supervisor solely because of the supervisor’s position.

Ward v. Taylor · filed 2009-10-15

The District Court also correctly pointed out that respondeat superior liability does not exist in the § 1983 context.
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Section 1983 does not impose supervisory liability based solely on a supervisor’s decision not to reprimand a subordinate officer after an alleged violation.

Peschel v. City of Missoula ex rel. Missoula Police Department · filed 2009-10-15

A single decision by a supervisor not to reprimand a subordinate officer, without more, is not sufficient to establish the type of ratification that would lead to liability under § 1983.
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Section 1983 does not permit a failure-to-supervise claim when the supervised officer did not use excessive force.

Sanchez v. Director McCray · filed 2009-10-19

Finally, because there was no genuine issue of material fact as to whether Francis used excessive force by pepper spraying Sanchez, the district court correctly granted summary judgment in favor of Meneses on the failure to supervise claim, which was premised upon Francis’s alleged use of excessive force.
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Section 1983 does not impose liability on a supervisor solely because of the supervisor’s position; the plaintiff must allege the defendant’s personal involvement in the deprivation.

Johnson v. Derose · filed 2009-10-20

It is well settled that liability under § 1983 may not based on the doctrine of respondeat superior.
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Section 1983 does not impose liability on supervisors solely because of their positions; they cannot be held liable under a respondeat superior theory.

Fails v. DeShields · filed 2009-10-22

Additionally, it is clear that the defendants Fails named took no part in his medical treatment; even if a constitutional violation had occurred, they could not have been liable for it under a respondeat superior theory.
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Section 1983 permits supervisory liability when a supervisor creates or allows a policy or custom under which a constitutional violation occurs.

FELIX-TORRES v. Graham · filed 2009-10-23

As explained above in Part III.B. of this Decision and Order, under the third prong for supervisory negligence, supervisors may be found liable if they created or allowed the policy or custom under which the incident occurred.
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Section 1983 requires evidence that a supervisor personally caused a constitutional violation or knew that subordinates were violating the plaintiff’s rights.

Smith v. Woodford · filed 2009-10-23

The district court properly granted summary judgment on the claims against Director Woodford because Smith failed to raise a triable issue as to whether she personally decided his inmate appeal, acted in other ways to cause his constitutional rights to be violated, or knew that her subordinates ... were violating his rights.
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Section 1983 supervisory liability fails when the underlying claims against the subordinate are without merit, precluded, or waived.

Miller v. Nichols · filed 2009-11-04

Finally, because all claims against defendant Nichols are either without merit, precluded, or waived, any claim of supervisory liability against defendant Harvey must also fail.
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Section 1983 requires proof of deliberate indifference to hold a supervisor liable for failing to supervise subordinates.

Graham v. Nadeau, et al. · filed 2009-11-09

Graham’s claims against Blaisdell and Curry appear to be based on a generalized contention that they failed to properly supervise Loven and Nadeau. These types of claims require proof of deliberate indifference.
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Section 1983 does not impose supervisory liability on a warden absent notice of a pattern of unconstitutional acts by subordinates.

Norman v. Schuetzle · filed 2009-11-09

Warden Sehuetzle cannot be held liable under a supervisory theory absent notice of a pattern of unconstitutional acts by his subordinates, see Andrews v. Fowler, 98 F.3d 1069, 1078 (8th Cir.1996), and the information known by the individual case workers cannot be imputed to the Warden under the facts of this case.
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Section 1983 requires personal involvement to hold a supervisor liable; respondeat superior alone is insufficient.

Tindell v. Beard · filed 2009-11-10

Tindell’s general claims against defendants who act as supervisors were also properly dismissed. He failed to allege any personal involvement and instead premised liability on a theory of respondeat superior.
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Section 1983 requires an affirmative link between a supervisor’s acts or omissions and a subordinate’s constitutional violation; general allegations of failure to train, supervise, or discipline are insufficient.

Torres-Santiago v. Díaz-Casiano · filed 2009-11-16

Aside from the absence of disciplinary action on the administrative complaint, the plaintiffs have not offered any other evidence in support of their assertions against Toledo, and further, they have established no affirmative link between Toledo’s acts or omissions and his subordinates’ alleged violation of the plaintiffs’ constitutional rights. Rather, the plaintiffs only set forth generally that Toledo failed to train, supervise, and discipline officers under his control. Therefore, the plaintiffs have failed to allege a plausible entitlement to relief under Section 1983.
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Section 1983 does not impose liability on a supervisor solely because a subordinate violated someone’s rights.

Smith v. Kenny · filed 2009-11-18

Similarly, a plaintiff cannot bring a § 1983 claim against a supervisor only on a theory of supervisor liability.
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Section 1983 does not permit vicarious liability; a supervisor who did not personally participate may be liable when widespread abuse put the supervisor on notice and the supervisor failed to correct it.

Campbell v. Correctional Officer · filed 2009-11-20

Campbell acknowledges the longstanding rule that § 1983 actions do not permit theories of vicarious liability. ... This one incident, however, is not enough to meet the rigorous standard for supervisory liability in this circuit.
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Section 1983 does not impose supervisory liability based solely on respondeat superior.

Rose v. Scott · filed 2009-11-23

Principles of respondeat superior do not apply to section 1983 suits, see Ashcroft v. Iqbal, 129 S. Ct. 1937, 1948–49 (2009); therefore, Strubeck is not liable for Hodge’s actions.
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Section 1983 supervisory liability requires an underlying constitutional violation by the supervised officers.

Tamez v. Manthey · filed 2009-12-02

Because no reasonable jury could find that either the detectives or the jailers violated Tamez’s constitutional rights, there can be no supervisor liability imposed on Chief Castillo or Supervisor Manthey, so the district court properly granted them summary judgment.
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Section 1983 does not permit supervisory liability when the underlying constitutional or statutory violation is not established.

Mann v. Taser International, Inc. · filed 2009-12-02

As such, Plaintiffs’ claims under a theory of supervisory liability fail because the underlying §1983 claims fail.
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Section 1983 permits personal liability for a supervisor who participates in or directs a constitutional violation, or knows of one and fails to intervene.

Schmidt v. City of Seattle (Spd) · filed 2009-12-04

Supervisors are only personally liable for damages under 42 U.S.C. § 1983 when the evidence shows that they participated in, directed, or knew of the alleged constitutional violations, and failed to intervene to prevent them.
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A supervisor may be liable under § 1983 if she affirmatively participates in a constitutional deprivation or implements an unconstitutional policy that causes it.

Wernecke v. Garcia · filed 2009-12-15

Under § 1983, “a supervisory official may be held liable ... only if (1) [s]he affirmatively participates in the acts that cause the constitutional deprivation, or (2) [s]he implements unconstitutional policies that causally result in the constitutional injury.”
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Section 1983 supervisory liability requires evidence that the supervisor knew of or acquiesced in the alleged misconduct.

Calderone v. Glenn Chrisman, Chief of Police · filed 2009-12-29

The sheriff negated an essential element of Mr. Calderone’s claim, namely the sheriff’s knowledge of or acquiescence in the incidents in question, so the burden of production shifted to Mr. Calderone, who failed to produce any countervailing evidence.
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Section 1983 does not impose liability on a supervisor merely for holding a supervisory position or failing to respond to a prisoner’s complaints.

Rosales v. Kikendall · filed 2010-01-06

Neither Kirkpatrick’s supervisory status nor his alleged failure to respond to plaintiffs complaints is enough to render him liable under § 1983.
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Section 1983 permits supervisory liability when a supervisor affirmatively participates in a constitutional deprivation or implements an unconstitutional policy that causes one.

Wernecke v. TX Dept Fam & Prtc · filed 2010-01-06

Under § 1983, “a supervisory official may be held liable . . . only if (1) [s]he affirmatively participates in the acts that cause the constitutional deprivation, or (2) [s]he implements unconstitutional policies that causally result in the constitutional injury.” Gates, 537 F.3d at 435.
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Section 1983 requires a supervisor sued in an individual capacity to be personally involved in the constitutional violation; supervisory position alone does not establish liability.

Kornegay v. New York · filed 2010-01-07

Those allegations are not enough to establish Goord’s or Wright’s personal involvement in any of the alleged constitutional deprivations here. For one thing, it is clear that defendants’ supervisory positions alone are not enough to render them liable for damages in a § 1983 action.
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Section 1983 permits monetary damages against a supervisory official only when the official was personally involved in the unconstitutional conduct.

Henry v. Lempke · filed 2010-01-20

Where, as here, monetary damages are sought pursuant to Section 1983, supervisory officials may only be held liable for constitutional violations where they were personally involved in unconstitutional conduct.
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Section 1983 does not impose vicarious liability on supervisors; a failure to train or supervise requires a causal link to the rights violation and deliberate indifference.

Reyes Ex Rel. Estate of Ceballos v. Bridgwater · filed 2010-01-22

As to the failure to supervise and train claim, we note that § 1983 does not provide for any form of vicarious or respondeat superior liability. See Estate of Davis v. City of N. Richland Hills, 406 F.3d 375, 381 (5th Cir. 2005). Instead, liability is proper when “(1) the supervisor either failed to supervise or train the ... subordinate official; (2) a causal link exists between the failure to train or supervise and the violation of the plaintiff’s rights; and (3) the failure to train or supervise amounts to deliberate indifference.”
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Section 1983 does not impose supervisory liability based on respondeat superior.

Giles v. MEDICAL CONTRACTORS CMS · filed 2010-01-26

As is well established, supervisory liability cannot be imposed under § 1983 on a respondeat superior theory.
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Section 1983 permits supervisory liability only when a subordinate’s constitutional violation is affirmatively linked to the supervisor’s action or inaction.

Brenes-Laroche v. Davila · filed 2010-01-26

Under section 1983, a supervisory official may be held liable for his subordinates’ behavior only if (1) his subordinates’ behavior results in a constitutional violation; and (2) the official’s action or inaction was affirmatively linked to that behavior such that it could be characterized as supervisory encouragement, condo-nation or acquiescence or gross negligence amounting to deliberate indifference.
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Section 1983 does not impose liability on supervisors solely because of their subordinates’ conduct.

Green v. Tudor · filed 2010-01-29

Liability of supervisory officers under 42 U.S.C. § 1983 cannot be based upon a respondeat superior theory.
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Section 1983 requires personal involvement or a policy causing the constitutional violation to impose supervisory liability.

Green v. Herbert · filed 2010-02-01

Plaintiff has also asserted claims against a number of supervisory officials, alleging that they failed to remedy the constitutional violations alleged here, or that they maintained policies that allowed those violations to occur. To the extent that the Court has found that the underlying constitutional claims are subject to dismissal, these claims fail as well. ... With respect to the surviving excessive-force and due process claims, plaintiffs claims against the defendant supervisory officials must also be dismissed. ... The mere fact that other incidents, involving other inmates, may have occurred, however, does not mean that the supervisory defendants were on notice of them, that they tolerated staff assaults on inmates, or that they were otherwise personally involved in the violation that forms the basis of plaintiffs excessive-force claim here. ... In the absence of either prior notice to the defendants of an unconstitutional practice, or some policy that they maintained that allowed such practices to occur unchecked, plaintiffs claim against the supervisory defendants must fail.
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Section 1983 does not provide relief under a respondeat superior theory.

Field v. Corrections Corp. of America Inc. · filed 2010-02-11

Field has not named the particular defendants responsible for the alleged violation, and relief under § 1983 is not available under a respondeat superior theory.
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Section 1983 does not impose supervisory liability based on respondeat superior or vicarious liability.

Staley v. Owens · filed 2010-02-24

It is well established in this Circuit that supervisory officials are not liable under § 1983 for the unconstitutional acts of their subordinates on the basis of respondeat superior or vicarious liability. ... Supervisory liability under § 1983 occurs only when “the supervisor personally participates in the alleged unconstitutional conduct or when there is a causal connection between the actions of a supervising official and the alleged constitutional deprivation.”
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Section 1983 supervisory liability requires an underlying constitutional violation by someone under the supervisor’s control.

Lepper v. Nguyen · filed 2010-02-26

Finally, Lepper’s supervisory liability claims against Willis and Singer fail because Lepper has not shown a constitutional violation by persons under their supervision or control.
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Section 1983 requires a plaintiff alleging supervisory liability to plead an affirmative link between the supervisor and the alleged deprivation; supervisory position alone is insufficient.

Thomas v. Barela · filed 2010-03-02

As for the Eighth Amendment claims, 2 the district court correctly held that Mr. Thomas had the burden of pleading that the defendants had an affirmative link to the events about which he complains.
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Section 1983 does not impose liability on a supervisor solely because of a subordinate’s conduct.

Richardson v. Johnson · filed 2010-03-02

Because § 1983 does not provide for liability under a theory of respondeat superior, id. at 691, the district court properly dismissed this claim.
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Section 1983 permits a claim against a supervisor who has authority to stop a known constitutional violation by a subordinate but fails to do so.

Keating v. City of Miami · filed 2010-03-02

A failure to stop claim under a theory of supervisory liability only requires that the supervisor (1) have the ability to prevent or discontinue a known constitutional violation by exercising his or her authority over the subordinate who commits the constitutional violation, and (2) subsequently fails to exercise that authority to stop it.
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Section 1983 permits individual liability for a supervisor who directly participates in a constitutional violation or fails to train or supervise the subordinate who caused it.

Giron v. City of Alexander · filed 2010-03-05

A supervisor may be held individually liable under § 1983 if he directly participates in the constitutional violation or if he fails to train or supervise the subordinate who caused the violation.
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Section 1983 does not impose liability on a supervisor without evidence of personal involvement in the alleged constitutional violation or a policy or custom the supervisor allowed to continue.

Price v. Reilly · filed 2010-03-08

Because there is no evidence in the record that Reilly was personally involved in any of the alleged constitutional violations or that there was a custom or policy of allowing such constitutional violations (and that Reilly allowed such custom or policy to continue), no rational jury could find Reilly liable for any of plaintiffs deliberate indifference claims.
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Section 1983 requires a supervisor’s personal involvement in the alleged violation; supervisory status alone does not establish liability.

Bridgewater v. Taylor · filed 2010-03-08

Here, Bridgewater provides nothing beyond the bare assertion that Wilson was Taylor’s supervisor to demonstrate that Wilson falls into any of these categories of personal involvement.
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Section 1983 permits supervisory liability when an official knows of and acquiesces in subordinates’ constitutional violations.

Hawkins v. Brooks · filed 2010-03-09

However, a supervisory official can be found liable under § 1983 if it is shown that he had knowledge of and acquiesced in his subordinates’ violations.
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Section 1983 does not permit liability based solely on a defendant’s supervisory position.

Dodge v. Shoemaker · filed 2010-03-11

Without the requisite factual allegations, the First and Fourth Claims seek to impose liability under a theory of respondeat superior, which is not sustainable under § 1983.
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Section 1983 permits supervisory liability when a supervisor’s deliberate inaction is causally linked to a constitutional injury.

Mitchell v. Rappahannock Regional Jail Authority · filed 2010-03-16

Here the allegations are much more specific with a clear causal link as the harm is tied directly to the inaction of the Defendants.
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Section 1983 permits liability when a supervisor’s own deliberate indifference deprives someone of the protected liberty interest in bodily integrity.

Sandra T.E. v. Grindle · filed 2010-03-17

When a state actor’s deliberate indifference deprives someone of his or her protected liberty interest in bodily integrity, that actor violates the Constitution, regardless of whether the actor is a supervisor or subordinate, and the actor may be held liable for the resulting harm.
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Section 1983 permits supervisory liability when supervisors actively participate in an alleged constitutional violation.

TADCO Construction Corp. v. Dormitory Authority · filed 2010-03-19

At this stage, this allegation is sufficient to state a § 1983 claim for supervisory liability. ... Because DeMartino alleges that Kemp and Cinelli actively participated in Middleton’s actions, he has adequately pled their liability.
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Section 1983 permits a retaliation claim against supervisors alleged to have ratified subordinates’ conduct and directed retaliatory action themselves.

Patterson v. Godward · filed 2010-03-19

Even defendants McQuiggan and Tribley who, as supervisors, are liable for the actions of their subordinates only under specific and limited circumstances, see Miller v. Calhoun County, 408 F.3d 803, 817 n.3 (6th Cir. 2005), are alleged to have ratified the behavior of their subordinates and, in some cases, directed specific retaliatory action towards Patterson.
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Section 1983 requires a claim against a sheriff to allege that the sheriff enacted or enforced a policy, custom, or practice that caused the denial of constitutional rights.

Cantrell v. Arpaio · filed 2010-03-26

The district court properly dismissed the claims against Sheriff Arpaio for failure to state a claim because Cantrell failed to allege that Arpaio enacted or enforced a particular policy, custom, or practice that resulted in denial of Cantrell’s constitutional rights.
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Section 1983 permits supervisory liability based on a supervisor’s own acts or omissions, not merely the subordinate’s conduct.

Igartúa v. Toledo · filed 2010-03-29

Under Section 1983, supervisory liability cannot be based on a respondeat superior theory, but instead it can only be based on the supervisor’s own acts or omissions.
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Section 1983 requires a prison official’s personal involvement to state a failure-to-protect claim, including when the official is a supervisor.

Wilkins v. Poole · filed 2010-03-30

In addition to knowledge of the threat of danger to the inmate, personal involvement is also necessary to state a claim for failure to protect against prison officials.
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Section 1983 permits supervisory liability when an official knew or should have known that inadequate supervision posed a substantial risk of constitutional violations, consciously disregarded that risk, and thereby caused a subordinate’s violation.

Beatty v. Davidson · filed 2010-03-31

To prevail on a claim of supervisory liability, a plaintiff must show some evidence that supervisory officials knew or should have known of a substantial risk that constitutional rights would be violated due to their lack of supervision, that the officials consciously disregarded the risk by failing adequately to supervise, and that such disregard caused a constitutional violation committed by subordinates.
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Section 1983 permits liability against prison supervisors only if they knew of a serious risk to an inmate’s health and disregarded it.

Maddox v. Jones · filed 2010-04-06

Even if he had evidence of constitutional violations on the part of the prison medical staff, Zwier and Pollard could be held liable only if they knew Maddox’s condition was serious and yet disregarded it.
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Section 1983 supervisory liability requires direct participation in a constitutional violation or a causal connection between the supervisor and the violation.

Granda v. Schulman · filed 2010-04-07

Further, he failed to allege a causal connection in this regard sufficient to state a claim against Dr. Schulman. See Gonzalez v. Reno, 325 F.3d 1228, 1234 (11th Cir. 2003) (discussing § 1983 liability under a theory of supervisory liability which requires either direct participation in the constitutional violation or a causal connection between the actor and the supervisor).
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Section 1983 makes supervisors liable only for their own misconduct, not solely for the misconduct of their subordinates.

Whitson v. Stone County Jail · filed 2010-04-22

In a § 1983 case, an official "is only liable for his . . . own misconduct" and is not "accountable for the misdeeds of [his] agents" under a theory such as respondeat superior or supervisor liability. ... These defendants are thus liable only if they personally displayed deliberate indifference to the risk that Whitson would be assaulted during the transfer.
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Section 1983 requires a causal connection between a supervisor’s actions and the alleged constitutional violation.

Duff v. Steub · filed 2010-04-29

To the extent Duff asserts a supervisor liability claim, Duff’s complaint does not allege a causal connection between the allegedly unconstitutional medical care and the “Chief Health Official’s” supervisory actions, such as failure to act in the face of notice of widespread abuse, the implementation of a custom or policy, or a direction to subordinates.
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Section 1983 permits suits against state actors for federal rights violations and imposes supervisory liability only for personal participation or a causal connection.

Doe v. School Bd. of Broward County, Fla. · filed 2010-04-27

It is well established in this circuit that supervisory officials are not liable under § 1983 for the unconstitutional acts of their subordinates” unless the “supervisor personally participates in the alleged constitutional violation” or “there is a causal connection between actions of the supervising official and the alleged constitutional deprivation.”
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Section 1983 requires an affirmative link between a supervisor’s own conduct or inaction and a subordinate’s constitutional violation; supervisory status alone does not create liability.

González-Pérez v. Toledo-Dávila · filed 2010-05-04

Absent such evidence, the motion for judgment as a matter of law must be granted since the plaintiff has been fully heard on the merits of his case and a jury would be left to reach but one conclusion, that there was no affirmative link between any action or omission on the part of Pedro Toledo-Dávila and the violation of plaintiffs rights.
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Section 1983 requires factual allegations tying a supervisor personally to a subordinate’s unconstitutional conduct.

Cintron-Arbolay v. Cordero-Lopez · filed 2010-05-05

Without further factual allegations tying Cordero personally to his subordinate’s unconstitutional behavior, the court must GRANT Defendants’ motion on this ground and dismiss Plaintiffs Section 1983 claim against co-defendant Cordero.
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Section 1983 does not impose supervisory liability when the officers committed no constitutional violation.

Meier v. County of Presque Isle · filed 2010-05-06

Here, because no constitutional violation occurred, the supervisors are not liable.
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Section 1983 supervisory liability requires more than a supervisor’s mere knowledge of a subordinate’s constitutional violation.

Sommer v. United States · filed 2010-05-10

To support a § 1983 claim for supervisory liability, a plaintiff must allege more than mere knowledge of a subordinate’s violation of the plaintiffs constitutional rights.
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A § 1983 plaintiff who does not allege a supervisor’s personal participation must allege a causal connection between the supervisor’s actions and the constitutional deprivation.

Watson v. Lockette · filed 2010-05-12

Absent personal participation, a § 1983 plaintiff must allege “a causal connection between actions of the supervising official and the alleged constitutional deprivation,” such as a history of widespread abuse that put the supervisor on notice of constitutional violations or a custom or policy of the ... supervisor that results in the constitutional violation.
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Section 1983 does not make supervisors personally liable for damages based solely on their positions; liability requires their own involvement in unconstitutional conduct.

Colvin v. Caruso · filed 2010-05-13

Allegations of respondeat superior do not sustain a § 1983 claim against state employees in their individual capacities, meaning that officials are personally liable for damages under that statute “only for their own unconstitutional behavior.”
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Section 1983 permits supervisory liability when a supervisor participates in or directs a subordinate’s constitutional violation, or knows of it and fails to prevent it; a place in the chain of command alone is insufficient.

Couch v. Cate · filed 2010-05-14

In a § 1983 claim, “a supervisor is liable for the acts of his subordinates ‘if the ... supervisor participated in or directed the violations, or knew of the violations of subordinates and failed to act to prevent them.’” Preschooler II v. Clark County Sch. Bd. of Trustees, 479 F.3d 1175, 1182 (9th Cir. 2007) (quoting Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989)).
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Section 1983 permits supervisory liability only when the official encouraged or directly participated in the unconstitutional conduct.

Wooler v. Hickman County, Kentucky · filed 2010-05-14

Moreover, Jailer Tarver is not liable as a supervisor of others at the Jail. See Leach v. Shelby County Sheriff, 891 F.2d 1241, 1246 (6th Cir. 1989) (stating that supervisory liability applies only if “the official either encouraged or in some way directly participated” in the unconstitutional conduct).
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Section 1983 supervisory liability requires evidence that an official set events in motion knowing, or having reason to know, they would lead to unlawful action.

Lewis v. Tripp · filed 2010-05-17

To survive summary judgment under Poolaw, Dr. Lewis had to come forward with some evidence that Dr. Tripp somehow knew or should’ve known that an unlawful investigation would follow from his decision to report Dr. Lewis’s unauthorized practice of medicine. In the record before us, there is no evidence of this.
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Section 1983 requires a supervisor’s personal involvement in the alleged constitutional violation; supervisory authority alone is insufficient.

Tafari v. McCarthy · filed 2010-05-24

5. The following claims are sua sponte DISMISSED: (a) the supervisory liability claims against defendant Miller regarding the urine-and-feces throwing incident and the mail tampering incident; ... (h) the retaliation claims against defendants Griffin and Healy based upon their conduct during disciplinary hearings.
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Section 1983 does not make a supervisor liable solely for a subordinate’s conduct; liability requires personal involvement in the deprivation.

Gray v. Taylor · filed 2010-05-28

The doctrine of respondeat superior (blanket supervisory liability) does not apply to actions filed under 42 U.S.C. § 1983.
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Section 1983 requires personal involvement by a defendant to establish supervisory liability for violating a plaintiff’s constitutional rights.

Park v. Veasie · filed 2010-06-09

However, it appears that, under a supervisory theory of liability, and even in light of Iqbal, personal involvement by a defendant remains the touchstone for establishing liability for the violation of a plaintiffs constitutional right.
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Section 1983 does not permit supervisory liability based on vicarious or respondeat superior liability.

Hemphill v. Hamilton · filed 2010-06-15

Because negligence does not give rise to a constitutional violation, and a supervisor may not be held liable under theories of vicarious or respondeat superior liability, the district court did not abuse its discretion by dismissing Hemphill’s complaint.
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Section 1983 permits supervisory liability under the Colon personal-involvement categories when those categories are consistent with the constitutional right at issue.

D'OLIMPIO v. Crisafi · filed 2010-06-15

Thus, the five Colon categories for personal liability of supervisors may still apply as long as they are consistent with the requirements applicable to the particular constitutional provision alleged to have been violated.
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Section 1983 permits liability when a supervisor directs staff to retaliate, even if the supervisor does not personally carry out the act.

Jackson v. Raemisch · filed 2010-06-21

While Lind was not personally involved in writing the report, she may be held liable on these facts for directing her staff to take a retaliatory action in violation of § 1983.
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Section 1983 does not impose vicarious liability on supervisors; a plaintiff must plead each supervisor’s own actions that violated the Constitution.

Major Tours, Inc. v. Colorel · filed 2010-06-22

The Complaint therefore must be dismissed as against those officials because vicarious liability is inapplicable to § 1983 suits; “a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.”
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Section 1983 requires evidence that a supervisor personally acted or failed to act unconstitutionally; a subordinate’s conduct alone does not establish supervisory liability.

Simmons v. Navajo County, Ariz. · filed 2010-06-23

To survive summary judgment, the Simmonses must therefore adduce evidence that Lieutenant Reynolds, Commander Burke, Sheriff Butler, and Dr. Kartchner themselves acted or failed to act unconstitutionally, not merely that a subordinate did.
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Section 1983 does not impose liability on supervisors solely because of their supervisory positions.

Hartmann v. Carroll · filed 2010-06-23

It appears that Pierce and Carroll were named as defendants based upon their supervisory positions and, as discussed above, § 1983 liability cannot lie under a theory of respondeat superior.
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Section 1983 does not impose liability on a supervisor solely for failing to supervise; the complaint must plausibly allege the supervisor’s involvement in a constitutional violation.

Nelson v. Skehan · filed 2010-07-13

Nelson’s claim that certain City of Lafayette police officers failed in their supervisory duties fails for the same reasons—there is no supervisory liability under § 1983 and there are no plausible allegations of acquiescence in a constitutional violation.
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Section 1983 does not impose liability solely because a defendant is a supervisor; the defendant must be personally involved in the alleged retaliation.

Smith v. Husz · filed 2010-07-14

But § 1983 does not allow actions against persons merely because of their supervisory roles, ... and Smith has not otherwise shown that these defendants were personally involved in any retaliation against him.
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Section 1983 does not make prison supervisors liable solely because they supervise someone who violated a prisoner’s rights.

Langford v. Norris · filed 2010-07-20

As the plaintiffs concede, prison supervisors such as Byus cannot be held liable under § 1983 on a theory of respondeat superior.
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Section 1983 permits liability for a supervisor’s failure to train, discipline, or control a subordinate when the supervisor knew of the misconduct or a similar prior pattern and acted in a way that could signal approval.

Zion v. Nassan · filed 2010-07-23

A supervisor’s failure “properly to train, discipline or control” can only form the basis for § 1983 liability “if the supervisor (1) either knew contemporaneously of the subordinate’s offending behavior or knew of prior pattern of similar incidents or circumstances and (2) acted in a manner that reasonably could be found to communicate a message of approval to the subordinate.”
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Section 1983 permits supervisory liability when pleaded facts plausibly show that a supervisor caused or acquiesced in subordinates’ constitutional violations.

Collins v. Brewer · filed 2010-07-23

Taken as true, plaintiffs have pled enough facts to state a claim of supervisory liability against defendant Brewer that is plausible on its face.
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Section 1983 does not impose vicarious liability on a sheriff who was not personally involved in the alleged constitutional violation.

Steele v. Rowles · filed 2010-08-04

The district court did not err in holding that Rowles was not personally involved in the alleged constitutional violation and, therefore, he could not be held liable based on a vicarious liability theory.
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Section 1983 requires contemporaneous personal knowledge and acquiescence to hold a supervisor liable; knowledge gained after the alleged abuse is insufficient.

Robinson v. Danberg · filed 2010-08-05

Contemporaneous, personal knowledge and acquiescence, not after the fact knowledge, is required for the imposition of § 1983 liability.
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Section 1983 does not impose supervisory liability through respondeat superior; a supervisor must at least implicitly authorize, approve, or knowingly acquiesce in the unconstitutional conduct.

Spangler v. Wenninger · filed 2010-08-06

Nonetheless, liability under § 1983 cannot be based on the doctrine of respondeat superior. ... “At a minimum a plaintiff must show that the [supervising] official at least implicitly authorized, approved, or knowingly acquiesced in the unconstitutional conduct of the offending officers.” ... Accordingly, there are genuine issues of material fact concerning Defendants’ supervisory liability.
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Section 1983 permits a claim against a supervisor who is responsible for a policy that causes a constitutional injury, if the supervisor acts with the state of mind required for the underlying violation.

Dodds v. Richardson · filed 2010-08-06

A plaintiff may therefore succeed in a § 1983 suit against a defendant-supervisor by demonstrating: (1) the defendant promulgated, created, implemented or possessed responsibility for the continued operation of a policy that (2) caused the complained of constitutional harm, and (3) acted with the state of mind required to establish the alleged constitutional deprivation.
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Section 1983 permits supervisory liability under the five Colon categories of personal involvement when those categories are consistent with the requirements of the constitutional right at issue.

Qasem v. Toro · filed 2010-08-10

Thus, the five Colon categories supporting personal liability of supervisors still apply as long as they are consistent with the requirements applicable to the particular constitutional provision alleged to have been violated.
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Section 1983 requires a defendant’s personal involvement in the alleged wrong; supervisory status alone does not establish liability.

Quarles v. PALAKOVICH · filed 2010-08-10

Liability under § 1983 is personal in nature and can only follow personal involvement in the alleged wrongful conduct shown through specific allegations of personal direction or of actual knowledge and acquiescence in the challenged practice.
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Section 1983 does not impose liability on a supervisor merely because a subordinate committed the alleged violation.

Woodard v. Dasrat · filed 2010-08-13

The doctrine of respondeat superior does not apply in § 1983 actions, Goebert v. Lee County, 510 F.3d 1312 (11th Cir. 2007), and the complaint does not allege that McCollum instituted a custom or policy that resulted in Dasrat’s deliberate indifference to Woodward’s constitutional rights or directed Dasrat falsely to represent to the Florida court that the evidence for DNA testing no longer existed.
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Section 1983 does not impose supervisory liability based solely on a supervisor’s position; the supervisor must be personally involved in the alleged wrongdoing.

Justice v. MACHTINGER · filed 2010-08-16

Plaintiffs retaliation claim is nothing more than an allegation of supervisor liability, which is not cognizable in a § 1983 action.
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A § 1983 claim based on a supervisor’s failure to train or supervise requires allegations that the supervisor knew of deficiencies that endangered detainees.

Robertson v. District of Columbia · filed 2010-08-16

In sum, absent any allegation that the Chief Lanier was subjectively aware of any deficiencies in training, supervision or measures to ensure the safety of detainees like the decedent, the complaint fails to state a § 1983 claim against Chief Lanier for a Fifth Amendment violation.
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Section 1983 supervisory liability requires evidence that the supervisor knew of the misconduct and facilitated, approved, condoned, or turned a blind eye to it.

Trentadue v. Redmon · filed 2010-08-18

Redmon’s liability under § 1983 as Cole’s supervisor requires some evidence that he knew about Cole’s sexual misconduct and facilitated, approved, condoned, or turned a blind eye to it.
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A § 1983 supervisor claim requires a triable issue that the supervisor failed to supervise adequately or implemented an unconstitutional policy.

Parthemore v. Tilton · filed 2010-08-27

The district court properly granted summary judgment on the claims against defendants Tilton and Campbell because Parthemore did not raise a triable issue as to whether these defendants, in their supervisory capacities, either failed to adequately supervise the handling of his initial agency appeal or implemented an unconstitutional policy.
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Section 1983 does not impose individual liability on a supervisory official solely for ignoring a letter protesting past unconstitutional conduct.

Platt v. The Inc. Vill. of Southampton · filed 2010-08-30

We cannot say, however, that an allegation that a supervisory official ignored a letter protesting past unconstitutional conduct is, without more, sufficient to state a claim that the official was “personally involved” in the unconstitutional conduct.
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Section 1983 does not impose supervisory liability based solely on a supervisor’s position; the supervisor must be personally involved in the alleged violation.

Beebe v. Birkett · filed 2010-09-03

The magistrate judge also agreed that Wardens Smith and Birkett should be dismissed from this suit because they were not personally involved in the alleged violations, since section 1983 supervisory liability cannot be predicated on respondeat superior and there was no evidence that these defendants were personally involved in the alleged constitutional violations. ... As noted above, the plaintiff has not filed objections, so the Court will adopt that portion of the recommendation that grants the motion for summary judgment as to all defendants in their official capacity, as to defendants Smith and Birkett on all claims, and as to the plaintiffs preDecember 2, 2005 kosher meal claims.
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Section 1983 requires personal involvement or an affirmative link between a supervisor’s conduct and a subordinate’s constitutional violation; supervisory status alone does not establish liability.

Oquendo-Rivera v. Toledo · filed 2010-09-07

Plaintiffs must show that each individual defendant was involved personally in the deprivation of constitutional rights because no respondeat superior liability exists under section 1983. ... He adduced no evidence whatsoever related to these claims, either about policies, practices, customs, training methodologies, complaint systems and oversight, or anything else related to supervisory liability. ... As such, the Court DISMISSES Oquendo’s supervisory liability claim.
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A § 1983 claim against a sheriff must plausibly allege that the sheriff participated in the constitutional violation or created a policy or custom under which it occurred.

Kleehammer v. Monroe County · filed 2010-09-08

Thus, in order to plausibly plead a claim against the County and Sheriff O’Flynn, Plaintiff must allege either that O’Flynn, the Monroe County Sheriff, had a hand in the alleged constitutional violation, or created a policy or custom under which the unconstitutional practices occurred.
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Section 1983 requires an affirmative link between a supervisor and a subordinate’s constitutional violation for supervisory liability.

Hook v. Regents of the University of California · filed 2010-09-13

Thus, even if Montaño’s failure to be awarded the Internal Audit Group Leader position did somehow constitute actionable retaliation under § 1983, which we doubt, Reed cannot be liable because there is nothing which affirmatively links him to this action.
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Section 1983 supervisory liability requires each supervisor’s personal involvement in the alleged constitutional violation.

D'OLIMPIO v. Crisafi · filed 2010-09-13

To succeed in asserting such claims, D’Olimpio must demonstrate, among other things, that Nadel, Moffett, and Giglio were each personally involved in the constitutional violations alleged.
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Section 1983 does not impose supervisory liability when the subordinate committed no constitutional violation.

De'Lonta v. Fulmore · filed 2010-09-20

Here, because the complaint makes clear that defendant Officer Fulmore did not violate plaintiffs constitutional rights, Scott and Pearson cannot be liable in a supervisory capacity.
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Section 1983 supervisory liability requires a causal connection between the supervisor’s acts and the alleged constitutional deprivation.

Frank A. Howell, Sr. v. City of Lithonia · filed 2010-09-28

Thus, even if Blackmon lacked probable cause, Howell did not set forth the necessary causal connection between the acts of a supervising official and the alleged constitutional deprivation to establish supervisory liability under section 1983.
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Section 1983 requires facts showing a supervisor’s personal participation in a constitutional violation or a causal connection between the supervisor’s actions and the violation.

Young v. Nichols · filed 2010-10-04

Because Young did not allege facts sufficient to establish supervisory liability under § 1983, his amendment would have been futile.
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Section 1983 does not impose supervisory liability solely because a person oversees the alleged wrongdoer; the supervisor must be personally involved in the deprivation.

Turner v. Kastre · filed 2010-09-29

As is well established, supervisory liability cannot be imposed under § 1983 on a respondeat superior theory.
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Knowledge that a jail doctor mistreated nursing staff, by itself, did not establish the sheriff’s supervisory liability under § 1983 for inadequate medical care.

Brown v. Callahan · filed 2010-10-07

Neither the demanding test for supervisory § 1983 liability, however, nor the test for official qualified immunity has been factually demonstrated against Sheriff Callahan simply because he knew the jail doctor mistreated the nursing staff.
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A supervisory school official facing a § 1983 claim for a teacher’s sexual abuse of a student must have actual notice of the abuse; nonspecific reports of inappropriate behavior do not suffice.

Doe v. Flaherty · filed 2010-10-19

C.H.’s nonspecific statements of October 23, 2006, without more concrete information, do not constitute the type of notice required to impose § 1983 supervisory liability in this context.
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Section 1983 liability requires a supervisory defendant’s personal involvement in the alleged constitutional violation.

Peoples v. Schwarzenegger · filed 2010-10-29

The district court properly dismissed each of Peoples’s claims against those supervisory defendants who were not personally involved in any alleged constitutional violation.
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Section 1983 does not make supervisory officials liable for their subordinates’ unconstitutional acts solely because they supervise them.

Woody v. Sheriff Steve Cronic · filed 2010-11-01

Supervisory officials are not liable under § 1983 for the unconstitutional acts of their subordinates on the basis of respondeat superior or vicarious liability.
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Section 1983 does not impose respondeat superior liability on supervisors.

Porro v. Barnes · filed 2010-11-09

Just as § 1983’s plain language doesn’t authorize strict liability, it doesn’t authorize respondeat superior liability.
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Section 1983 does not permit a mayor to be held liable solely on a respondeat superior theory.

Hussein v. State of NJ · filed 2010-11-18

Mayor Healy cannot be sued under § 1983 on the basis of a respondeat superior theory.
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Section 1983 supervisory liability requires unconstitutional conduct by a subordinate.

Grose v. Correctional Medical Services, Inc · filed 2010-11-18

As shown above, however, there were no such violations; so these claims, which are derivative, fail. See McQueen v. Beecher Cmty. Schs., 433 F.3d 460, 470 (6th Cir. 2006) (“a prerequisite of supervisory liability under § 1983 is unconstitutional conduct by a subordinate of the supervisor”).
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Section 1983 allows supervisory liability when a supervisor’s own conduct contributes to a constitutional violation, including by condoning a subordinate’s conduct after learning of it through grievances.

Brown v. Englander, et al. · filed 2010-11-24

Accordingly, these defendants can be sued in their supervisory capacities under section 1983.
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Section 1983 supervisory liability requires facts showing that supervisors had notice of subordinates’ misconduct and were deliberately indifferent to or tacitly authorized it.

Bradshaw v. Harden · filed 2010-11-24

However, as noted by the district court, Bradshaw does not allege any facts that would have put defendants on notice that the policy was being violated. As such, Bradshaw cannot show that the supervisors demonstrated deliberate indifference to, or tacit authorization of, the conduct of their subordinates. Accordingly, the district court did not err in dismissing Bradshaw’s complaint insofar as it relied on a theory of supervisory liability.
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Section 1983 requires personal involvement, a sufficient causal connection, or a deficient policy to hold a supervisor liable; grievances filed with other officials alone do not establish individual liability.

Blackmon v. KUKUA · filed 2010-12-02

The Fifth Circuit has held that supervisory officials are not liable under § 1983 unless “there exists either (1) his personal involvement in the constitutional deprivation, or (2) a sufficient causal connection between the supervisor’s wrongful conduct and the constitutional violation.” ... Under these standards, Plaintiff cannot support an individual claim against Executive Director Livingston based simply on the fact that Blackmon filed grievances with officials at Garza East and that those officials failed to act.
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Section 1983 does not impose personal liability on an official solely because the official supervises the alleged wrongdoer.

Waker v. Brown · filed 2010-12-09

Section 1983 provides no basis for recovery on a theory of respondeat superior.
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Section 1983 does not make a supervisor liable solely because the supervisor is responsible for another person’s actions or omissions.

Flores v. Merced Irrigation District · filed 2010-12-09

Under no circumstances, however, is there respondeat superior liability under § 1983; that is, there is no liability under § 1983 solely because one is responsible for the actions or omissions of another.
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Section 1983 requires a plaintiff claiming that supervisors directed a constitutional violation to plead an actual violation by subordinates and a causal connection to the supervisors’ directions.

Santiago v. Warminster Township · filed 2010-12-14

Thus, any claim that supervisors directed others to violate constitutional rights necessarily includes as an element an actual violation at the hands of subordinates. In addition, a plaintiff must allege a causal connection between the supervisor’s direction and that violation, or, in other words, proximate causation.
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A supervisor faces liability under § 1983 for racial discrimination only if evidence shows personal involvement or actual knowledge of and acquiescence in others’ discriminatory conduct.

Peace-Wickham v. Walls · filed 2010-12-21

Claims that a supervisor participated in alleged discriminatory behavior must be supported by evidence of personal involvement by the supervisor, or evidence that the supervisor possessed actual knowledge of the discriminatory behavior of others and acquiesced to their improper conduct.
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Section 1983 does not impose supervisory liability without personal involvement or a policy that repudiates constitutional rights and causes the violation.

Tuft v. State of Texas · filed 2011-01-07

The district court properly dismissed Tuft’s claims against former TDCJ-ID Director Douglas Dretke, former Jester III Warden Brenda Chaney, and Jester III Assistant Warden Richard Leal in their individual capacities, as well as for vicarious or respondeat-superior liability. Tuft did not produce any summary judgment evidence showing these TDCJ officials were personally involved in the 2005 strip search or that they implemented a policy that was itself a repudiation of constitutional rights and the moving force of the constitutional violation.
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Section 1983 requires evidence of a supervisor’s personal involvement in an alleged rights violation to hold that supervisor individually liable.

Solomon v. Nassau County · filed 2011-01-07

Because the Plaintiff has not provided any evidence that Sposato and Reilly were “personally involved” in any alleged failure to maintain a safe prison environment, the Court dismisses the claims against Sposato and Reilly in their entirety.
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Section 1983 generally does not impose vicarious liability on supervisors unless state law imposes it.

Castro v. Melchor · filed 2011-01-07

Generally, respondeat superior or vicarious liability does not exists under § 1983 unless state law imposes such liability.
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Section 1983 does not support a claim against a supervisory defendant when the plaintiff has not established a violation of his constitutional rights.

Hunter v. Sterling · filed 2011-02-10

Because Hunter has not established a violation of his constitutional rights, he cannot likewise show that he will bring a claim upon which relief can be granted against one of the supervisory defendants.
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Section 1983 permits supervisory liability based on a supervisor’s own acts or omissions, but a supervisor’s position alone does not establish the required link to a constitutional violation.

Rodríguez-Sánchez v. Acevedo-Vilá · filed 2011-02-10

Under section 1983, supervisory liability can only be grounded on the supervisor’s own acts or omissions either through the supervisor’s direct participation in the unconstitutional conduct, or through conduct that amounts to condonation or tacit authorization. ... That affirmative link is missing.
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Section 1983 requires a supervisor’s personal involvement; general responsibility for prison operations is insufficient.

Reynolds v. Dormire · filed 2011-02-18

It is settled, however, that “a warden’s general responsibility for supervising the operations of a prison is insufficient to establish personal involvement.”
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Section 1983 does not make a supervisor liable solely for a subordinate’s misconduct.

Steven Gravley, Jr. v. Tretnik · filed 2011-02-23

We agree that, to the extent Gravley sought to hold Administrator Tretinik liable for the misconduct of subordinate officials, the complaint fails to state a claim.
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Section 1983 supervisory liability requires that a supervisor participated in or directed a constitutional violation, or knew of it and failed to prevent it.

Alvarez v. Horel · filed 2011-02-24

The district court properly dismissed Alvarez’s supervisory liability claims against defendants Tilton, Horel, and Kirkland because Alvarez failed to allege that these defendants “participated in or directed [any constitutional] violations, or knew of the violations and failed to act to prevent them.”
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Section 1983 does not make a supervisor liable solely because a subordinate may have violated someone’s rights.

Aranda v. Martel · filed 2011-02-28

The district court properly dismissed the action against Warden Martel because, contrary to Aranda’s contention, Warden Martel cannot be held liable under respondeat superior for the possible loss of mail.
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Section 1983 permits supervisory liability when an official consciously ignores complaints and allows racial harassment to continue.

Matusick v. Erie County Water Authority · filed 2011-03-01

Under this reading of Colon, then, the holding from Iqbal that government officials are responsible only for their own misconduct had no impact on the possibility that misconduct can result from an active, conscious decision to ignore complaints and to allow racial harassment to continue.
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Section 1983 requires an affirmative link between a supervisor’s action or inaction and a subordinate’s constitutional violation.

Moreno-Perez v. Toledo-Davila · filed 2011-03-04

The plaintiff has not shown the requisite “affirmative link” between the street-level conduct and the supervisory action or inaction.
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Section 1983 supervisory liability requires knowledge of a pervasive risk of constitutional injury, deliberate indifference or tacit approval, and a causal link to the plaintiff’s injury.

Greenan v. Board of Educ. of Worcester County · filed 2011-03-08

To establish supervisory liability under § 1983, a plaintiff must show: (1) that the supervisor had actual or constructive knowledge that his subordinate was engaged in conduct that posed “a pervasive and unreasonable risk” of constitutional injury to citizens like the plaintiff; (2) that the supervisor’s response to that knowledge was so inadequate as to show “deliberate indifference to or tacit authorization of the alleged offensive practices”; and (3) that there was an “affirmative causal link” between the supervisor’s inaction and the particular constitutional injury suffered by the plaintiff.
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Section 1983 permits supervisory liability when a supervisor’s contemporaneous knowledge and inaction show acquiescence in subordinates’ constitutional violations.

Nykiel v. Borough of Sharpsburg · filed 2011-03-09

This contemporaneous knowledge of possible offending acts as well as inaction on Chief Rudzki’s part could be interpreted by a reasonable juror as circumstances under which Chief Rudzki was aware of and acquiesced to Officer Duffy and Officer Mitchell’s actions and communicated a message of approval to the allegedly offending officers. For the foregoing reasons, summary judgment on supervisor liability will be denied.
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Notes 45901–46050 of 71,725, oldest cases first.

Which of these rulings fit your facts?

Describe your situation under 42 U.S.C. § 1983. Ezel checks it against the cases on this page and answers with citations.

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