A public officer or agent is not responsible for the misfeasances or position wrongs, or for the nonfeasances, or negligences, or omissions of duty, of subagents or servants or other persons properly employed by or under him, in discharge of his official duties

Government officials are not liable for the unconstitutional conduct of their subordinates under a theory of respondeat superior.

As early as 1888, the Supreme Court held that supervisory government officials could not be held personally liable for the wrongs of their subordinates when "[t] here is nothing in the evidence to connect the defendant personally with any such wrong."

Public officials in supervisory positions cannot simply be held vicariously liable for the acts of their subordinates.

"The Government itself is not responsible for the misfeasances, or wrongs, or negligences, or omissions of duty of the subordinate officers or agents employed in the public service; for it does not undertake to guarantee to any person the fidelity of any of the officers or agents whom it employs; since that would involve it, in all its operations, in endless embarrassments …