based on the incidents involving Holloman and Hutto, that a “custom” or “practice” of disciplining students for failing to recite the Pledge of Allegiance (or for engaging in a non-disruptive protest during the pledge) existed in the school district. Consequently, Holloman may not pursue his Speech Clause claim against the Board under this theory. In contrast, Allred’s practice of conducting a daily moment for silent prayer — which she actually referred to as a “ritual” — was sufficiently systematic to be considered a pattern or custom for which the Board may be held accountable. Our precedents are clear that, for constitutional violations to be sufficiently “widespread” for a governmental supervisor to be held liable, they need occur with frequency, see Brown, 906 F.2d at 671 (<HOLDING>); see also Greason v. Kemp, 891 F.2d 829, 837
holding that violations must be obvious flagrant rampant and of continued duration to hold a supervisor liable holding that a supervisor cannot be held personally liable for the unconstitutional conduct of a subordinate based on vicarious liability holding that an obvious joke told during an obvious comedy performance was not defamatory as a matter of law holding plaintiffs supervisor subject to suit holding that individual defendants may not be held liable for violations under title vii