AND · 42usc1983:causation
Because there is no respondeat superior in § 1983, a plaintiff must plead and prove that each Government-official defendant, through the official's own individual actions, has violated the Constitution (Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009)).
Exact element source
subjects, or causes to be subjected,Source:
docroot/ir/usc/title42.jsonl#title42_sec1983; Unicode character offsets [188:224] (end exclusive); SHA-256 88fe01322b9d94860a669ec452f558146e2745845070bc43583671ce12acb2bb.Routes and case patterns
| Route | Definition | Merits instance blocks | Distinct merits cases | Examples (up to 3 cases per count group) |
|---|---|---|---|---|
| Unclassified route provisional; 8 observed cases | no definition yet | 0 Satisfied 0; not satisfied 0; excluded context 8 | 0 | Used only in non-merits blocks (8). Excluded context examples:Dye v. City of Warren — 367 F. Supp. 2d 1175 (2005) · United States District Court for the Northern District of Ohio · 2005 — not reached · basis not recorded (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed) · applied/merits · not counted Thompson v. Community Action of Greater Wilmington, Inc. — 567 F. Supp. 1159 (1983) · United States District Court for the District of Delaware · 1983 — not reached · basis not recorded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/merits · not counted Kamenesh v. City of Miami — 772 F. Supp. 583 (1991) · United States District Court for the Southern District of Florida · 1991 — not reached · basis not recorded (42usc1983: author: Fable · not independently reviewed) · applied/merits · not counted |
| personal-involvement provisional; 2 observed cases | Whether this defendant personally took part in the deprivation. | 1 Satisfied 0; not satisfied 1; excluded context 1 | 1 | Johnson v. Caudill — 475 F.3d 645 (2007) · United States Court of Appeals for the Fourth Circuit · 2007 — not · conceded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/merits · counted Galloway v. County of Nassau — 141 F.4th 417 (2025) · Court of Appeals for the Second Circuit · 2025 — not reached · basis not recorded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/merits · not counted |
| supervisory-liability provisional; 2 observed cases | Whether a supervisor is liable for a subordinate's act through his own direction, policy or acquiescence. | 1 Satisfied 1; not satisfied 0; excluded context 1 | 1 | Dodson v. Polk County — 628 F.2d 1104 (1980) · United States Court of Appeals for the Eighth Circuit · 1980 — satisfied · pleaded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/merits · counted Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992 — satisfied · proved (42usc1983: author: Fable · QA: PASS (QA1, neov2/qa/cases-v1-QA1.md)) · applied/lower-court · not counted |
How courts decided this element
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Dye v. City of Warren — 367 F. Supp. 2d 1175 (2005) · United States District Court for the Northern District of Ohio · 2005 — not reached (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified route | No source quotation recorded for this block. |
| Thompson v. Community Action of Greater Wilmington, Inc. — 567 F. Supp. 1159 (1983) · United States District Court for the District of Delaware · 1983 — not reached (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified route | No source quotation recorded for this block. |
| Kamenesh v. City of Miami — 772 F. Supp. 583 (1991) · United States District Court for the Southern District of Florida · 1991 — not reached (42usc1983: author: Fable · not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / meritsCourt notes "numerous factual issues of responsibility and causation appear to remain" per defendant; left for trial. | Unspecified route | No source quotation recorded for this block. |
| Dodson v. Polk County — 628 F.2d 1104 (1980) · United States Court of Appeals for the Eighth Circuit · 1980 — satisfied · pleaded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | satisfied Counted merits instance applied / merits basis: pleaded; party: Offender Advocate and Board of Supervisors members; subject: party=Offender Advocate and Board of Supervisors members Pro se complaint read expansively; court flags that summary judgment on no-personal-involvement may follow if the rules had nothing to do with the defender's conduct. | supervisory/established-rules-and-procedures-subordinate-followed | The Polk County Offender Advocate and the Polk County Board of Supervisors, also named as defendants, were alleged to be responsible for Ms. Shepard’s actions because they established rules and procedures for her to follow in handling criminal appeals.Source: docroot/ir/caselaw/f2d_628.jsonl#/f2d/628/1104-01; Unicode character offsets [1762:2014] (end exclusive); SHA-256 d2c865685b00f7d491a6a0a10e31df9c82bf1a5e46d7bc2a6fe79468154f11bf.Whether the requisite personal involvement by the Offender Advocate in the claimed unconstitutional conduct was sufficiently alleged, however, is a separate issue which the District Court did not reach.Source: docroot/ir/caselaw/f2d_628.jsonl#/f2d/628/1104-01; Unicode character offsets [11175:11377] (end exclusive); SHA-256 d2c865685b00f7d491a6a0a10e31df9c82bf1a5e46d7bc2a6fe79468154f11bf.These allegations are sufficient, as a matter of pleading, to state a § 1983 claim against the Offender Advocate.Source: docroot/ir/caselaw/f2d_628.jsonl#/f2d/628/1104-01; Unicode character offsets [11817:11930] (end exclusive); SHA-256 d2c865685b00f7d491a6a0a10e31df9c82bf1a5e46d7bc2a6fe79468154f11bf.Similar allegations were made as to the involvement of the Polk County Board of Supervisors, and we hold that the complaint is sufficient to state a claim against the Board members for the same reason.Source: docroot/ir/caselaw/f2d_628.jsonl#/f2d/628/1104-01; Unicode character offsets [12056:12257] (end exclusive); SHA-256 d2c865685b00f7d491a6a0a10e31df9c82bf1a5e46d7bc2a6fe79468154f11bf. |
| Calabretta v. Floyd — 189 F.3d 808 (1999) · United States Court of Appeals for the Ninth Circuit · 1999 — not reached (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-QA1.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / meritsOfficer Schwall's responsibility for the strip search (he "backed off") is not separately analysed. | Unspecified route | No source quotation recorded for this block. |
| Johnson v. Caudill — 475 F.3d 645 (2007) · United States Court of Appeals for the Fourth Circuit · 2007 — not · conceded (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not Counted merits instance applied / merits basis: conceded; count: patrol-assignment and verbal equipment-request allegations; subject: count=patrol-assignment and verbal equipment-request allegations Footnote holding: workplace-condition complaints not tied to the sheriff's own acts cannot support individual-capacity liability. | requests-handled-by-subordinates-not-defendant | However, she alleges only that she informed other supervisors, not Sheriff Caudill, of her ongoing wish to work patrol.Source: docroot/ir/caselaw/f3d_475.jsonl#/f3d/475/0645-01; Unicode character offsets [16331:16450] (end exclusive); SHA-256 30727309c1ebc11dd668c942b1108b6857a301484b72823436c570f211451717.Similarly, Johnson describes a number of items of equipment that she requested verbally, but such requests were processed by office manager Sean Hurd, not Sheriff Caudill.Source: docroot/ir/caselaw/f3d_475.jsonl#/f3d/475/0645-01; Unicode character offsets [16451:16622] (end exclusive); SHA-256 30727309c1ebc11dd668c942b1108b6857a301484b72823436c570f211451717.These allegations may have been appropriate for a Title VII action, but lack sufficient connection to Sheriff Cau-dill’s actions to spawn individual-capacity liability under § 1983.Source: docroot/ir/caselaw/f3d_475.jsonl#/f3d/475/0645-01; Unicode character offsets [16623:16804] (end exclusive); SHA-256 30727309c1ebc11dd668c942b1108b6857a301484b72823436c570f211451717. |
| Henderson v. Glanz — 813 F.3d 938 (2015) · United States Court of Appeals for the Tenth Circuit · 2015 — not reached (42usc1983: author: Fable · not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / meritsSupervisory liability of the sheriff (notice + failure to respond) was the issue he tried to raise; not reviewable. | Unspecified route | No source quotation recorded for this block. |
| Galloway v. County of Nassau — 141 F.4th 417 (2025) · Court of Appeals for the Second Circuit · 2025 — not reached (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits party: each detective, as to the other detectives' conduct; subject: party=each detective, as to the other detectives' conduct Defendants argued they cannot be liable for acts they did not participate in (no failure-to-intervene when absent); court agrees with the principle but finds the district court never held otherwise, so nothing to decide. Special verdicts suggested to keep liability per-defendant. | no-liability-for-events-defendant-took-no-part-in | The district court 18 did not make the error the defendants urge us to correct.Source: docroot/ir/caselaw/f4th_141.jsonl#/f4th/141/417; Unicode character offsets [27318:27397] (end exclusive); SHA-256 ffd06c7c495fbf996a4a6d1e4a3336db8e40aa112435c30b895506a5be4e900f. |
| Hafer v. Melo — 502 U.S. 21 (1991) · Supreme Court of the United States · 1991 — not reached (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-QA1.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified route | No source quotation recorded for this block. |
| Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992 — satisfied · proved (42usc1983: author: Fable · QA: PASS (QA1, neov2/qa/cases-v1-QA1.md)) | Personal involvement / causal connection ("subjects, or causes to be subjected") | satisfied Excluded from merits counts applied / lower-court basis: proved; party: Mezo (supervisor on duty); subject: party=Mezo (supervisor on duty) Supervisor liability rests on the Magistrate's finding, left intact; the Court states no test for supervisory liability and uses the finding only to rebut the "isolated and unauthorized" argument. | supervisory/on-scene-supervisor-condoned-subordinates-force | He further testified that Mezo, the supervisor on duty, watched the beating but merely told the officers “not to have too much fun.”Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0001-01; Unicode character offsets [1002:1134] (end exclusive); SHA-256 312cc989003e278cd808b5781c7340ad0273605ed6762af44d590ac6ceae31cf.Indeed, there was testimony that McMillian and Woods beat another prisoner shortly after they finished with Hudson.Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0001-01; Unicode character offsets [16367:16482] (end exclusive); SHA-256 312cc989003e278cd808b5781c7340ad0273605ed6762af44d590ac6ceae31cf.Moreover, respondents ignore the Magistrate’s finding that Lieutenant Mezo, acting as a supervisor, “expressly condoned the use of force in this instance.”Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0001-01; Unicode character offsets [16724:16879] (end exclusive); SHA-256 312cc989003e278cd808b5781c7340ad0273605ed6762af44d590ac6ceae31cf. |
| Collins v. City of Harker Heights — 503 U.S. 115 (1992) · Supreme Court of the United States · 1992 — not reached (42usc1983: author: Fable · not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified route | No source quotation recorded for this block. |
| American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 — not reached (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed) | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified route | No source quotation recorded for this block. |
Court interpretations
interpretation
Whether the requisite personal involvement by the Offender Advocate in the claimed unconstitutional conduct was sufficiently alleged, however, is a separate issue which the District Court did not reach.
Dodson v. Polk County — 628 F.2d 1104 (1980) · United States Court of Appeals for the Eighth Circuit · 1980 (42usc1983: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
Whether the requisite personal involvement by the Offender Advocate in the claimed unconstitutional conduct was sufficiently alleged, however, is a separate issue which the District Court did not reach.Source:
docroot/ir/caselaw/f2d_628.jsonl#/f2d/628/1104-01; Unicode character offsets [11175:11377] (end exclusive); SHA-256 d2c865685b00f7d491a6a0a10e31df9c82bf1a5e46d7bc2a6fe79468154f11bf.Because there is no respondeat superior in § 1983, a plaintiff must plead and prove that each Government-official defendant, through the official's own individual actions, has violated the Constitution (Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009)).