liable and that “Defendants District of Columbia, MPD, Commander McCoy, the Watch Commander, Sgt. Gamble, USSS and Chief of the Uniformed Division” are “vicariously liable on the basis or [sic] respondeat superior for any violation of Mr. Powers’ civil and/or constitutional rights.” Compl. ¶ 32. As an initial matter, there is no vicarious liability for constitutional violations. This point of law is incontrovertible; it is directly established by Supreme Court and D.C. Circuit precedent. See Monell, 436 U.S. at 693, 98 S.Ct. 2018 (“[A] municipality cannot be held liable solely because it employs a tortfeasor — or, in other words, a municipality cannot be held liable under § 1983 on a respondeat superior theory.”); Int’l Action Ctr. v. United States, 365 F.3d 20, 27 (D.C.Cir.2004) (<HOLDING>); Arnold v. Moore, 980 F.Supp. 28, 35
holding that a supervisor cannot be held personally liable for the unconstitutional conduct of a subordinate based on vicarious liability holding officer personally liable because he agreed to personally guarantee payment on an account holding that no expert reports specifically addressing conduct of professional corporation and professional association were required when plaintiffs alleged only vicarious liability based on medical negligence of entities physicians explaining that the entities conduct is not measured by a medical standard of care but rather their liability was solely vicarious holding that individual defendants with supervisory control over plaintiff cannot be held personally liable under title vii holding supervisor personally liable for death of employee where supervisor personally arranged for employee to be dangled from the tines of a forklift over a vat of scalding water into which employee fell and died