First Circuit
Doan v. Bergeron, No. 15-CV-11725-IT, 2016 WL 5346935, at *8-9 (D. Mass. Sept. 23, 2016) (“A supervisor can be liable for the actions of his subordinates if he or she ‘is on notice’ to ‘ongoing violations’ and ‘fails to take corrective action.’”).
Camilo-Robles v. Hoyos, 151 F.3d 1, 5-6 (1st Cir. 1998) (“When a supervisor seeks qualified immunity in a section 1983 action, the ‘clearly established’ prong of the qualified immunity inquiry is satisfied when (1) the subordinate’s actions violated a clearly established constitutional right, and (2) it was clearly established that a supervisor would be liable for constitutional violations perpetrated by his subordinates in that context.”).
Eighth Circuit
Anderson v. Roberts, 823 F.2d 235, 239 (8th Cir. 1987) (citing Pearl v. Dobbs, below, and stating that “Sheriff Bolin is not entitled to summary judgment on the basis of qualified immunity”).
Pearl v. Dobbs, 649 F.2d 608, 609 (8th Cir. 1981) (stating that “although the doctrine of respondeat superior does not apply to [section] 1983 cases, a [section] 1983 plaintiff may maintain a theory of direct liability against a prison or other official if that official fails to properly train, supervise, direct or control the actions of a subordinate who causes the injury”).