See e.g., Murphy v. Town of Duxbury, 40 Mass.App.Ct. 513, 665 N.E.2d 1014, review denied, 423 Mass. 1105, 668 N.E.2d 356 (1996) (affirming grant of summary judgment on MCRA claim for lack of proof as there was no evidence that the Town officials were motivated other than by desire to enforce their interpretation of zoning laws). In addition, Cignetti’s claim against Healy fails because it is based solely on a theory of vicarious liability. Cignetti does not allege that Healy threatened him directly, but asserts that the “threats” allegedly made by Rossi can be attributed to Healy because Rossi was Healy’s agent. However, nothing in the record indicates that Rossi was acting at Healy’s direction or that Healy authorized or approved Rossi’s alleged “threats.” Cf. Alioto, 835 F.2d at 1175 (<HOLDING>). The MCRA claim against Fitzgerald also fails
holding that liability may not be imposed on supervisory personnel under  1983 where at best the plaintiff has merely claimed that the appellants were aware of alleged violation but did not take appropriate action holding that an employer alone is liable for a violation of title vii by supervisory employees holding that supervisory liability under  1983 requires a showing that the supervisory official at least implicitly authorized or approved or knowingly acquiesced in the unconstitutional conduct of the offending subordinate holding that employer may be held liable under  1981 for discrimination by supervisory employee holding supervisory personnel liable for  1983 violations only where evidence establishes that they authorized or approved the unconstitutional conduct