See Rodriguez v. Easter, No. 3:20-CV-1872 (SVN), 2022 WL 1205279, at *2 (D. Conn. Apr. 22, 2022) (“[I]n Tangreti, the Second Circuit held that, ‘after Iqbal, there is no special rule for supervisory liability. Instead, a plaintiff must plead and prove ‘that each Governmentofficial defendant, through the official's own individual actions, has violated the Constitution.'” (quoting Tangreti v. Bachmann, 983 F.3d 609, 618 (2d Cir. 2020) (citing Iqbal, 556 U.S. at 677)); Olivio v. United States, No. 20CV231(RPK)(MMH), 2022 WL 409720, at *5 (E.D.N.Y. Feb. 10, 2022) (“But there is no special rule for supervisory liability under Bivens; a plaintiff seeking to hold a supervisor liable must demonstrate that the supervisor directly violated his constitutional rights.”
However, a plaintiff must do more than "'allege the existence of physical or mental ailments'"; they must also "'show[ ] that these health problems rendered [them] unable to pursue [their] legal rights during the [relevant] time period.'" Olivio v. United States, No. 20-CV-231, 2022 WL 409720, *3 (E.D.N.Y. Feb. 10, 2022) (quoting Rhodes v. Senkowski, 82 F.Supp.2d 160, 173 (S.D.N.Y. 2000)); see also Valverde v. Stinson, 224 F.3d 129, 134 (2d Cir. 2000) ("The word 'prevent' requires the [litigant] to demonstrate a causal relationship between the extraordinary circumstances on which the claim for equitable tolling rests and the lateness of his filing, a demonstration that cannot be made if the [litigant], acting with reasonable diligence, could have filed on time notwithstanding the extraordinary circumstances"). "With respect to a medical condition, this requires the litigant to 'offer a particularized description of how her condition adversely affected her capacity to function generally or in relationship to the pursuit of her rights.'" Rivera v. Mucha, No. 3:21-CV-316, 2022 WL 1205203, *3 (D. Conn. Apr. 22, 2022) (quoting Bolarinwa v. Williams, 593 F.3d 226, 232 (2d Cir. 2010)).
Palompelli v. Smith, No. 20-CV-8070 (CS), 2022 WL 624421, at *3 (S.D.N.Y. Mar. 3, 2022) (dismissing Eighth Amendment claim against Koenigsmann based upon the assertion that he was “in charge overall”); see also Olivio v. United States, No. 20-CV-231 (RPK/MMH), 2022 WL 409720, at *5 (E.D.N.Y. Feb. 10, 2022) (explaining that the plaintiff “cannot state a claim” for deliberate medical indifference based on allegation that the prison officials were liable “because they were responsible as supervisors for formulating, adopting, and reviewing policies relating to the medical care of inmates.”) (internal quotation marks omitted)