discussed Cited "see, e.g." Mom's, Inc. v. Weber In a Bivens action, a supervisor can only be held liable for the acts of a subordinate “by proof of direct culpability in causing the injury either by directly authorizing it or by expressly or tacitly condoning by inaction a known pattern of comparable coworker conduct.” McWilliams v. Fairfax County Bd. of Supervisors, 72 F.3d 1191, 1197 (4th Cir.1996); see also White v. Downs, 112 F.3d 512 , 1997 WL 210858 , *4 (4th Cir.1997), cert denied, 522 U.S. 866 , 118 S.Ct. 175 , 139 L.Ed.2d 116 (1997).