Does a supervisor need to be physically present to be held liable?

Plaintiffs also cite to Shafer v. City of Boulder, 896 F. Supp. 2d 915 (D. Nev. 2012) for the proposition that supervisory defendants need not be physically present in order to be held liable. Oppo. at 28:24-29:3. It may be that supervisors need not be physically present to be held liable; however, just because a supervisor does not need to be physically present does not mean he is alleviated from the requirement that he personally participate in the alleged constitutional violations in some fashion. For example, in Shafer, even though the supervisor was out of town, the court noted that if he approved of or condoned of the acts at issue, he could still be held liable. 896 F. Supp. 2d at 936. Nonetheless, the

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