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Stevenson v. Nail — Fifth Circuit affirmed summary judgment dismissing a prisoner’s excessive-force claim

Unreported / Non-Citable

Case
Brandon Stevenson v. Lonnie Nail
Court
U.S. Court of Appeals for the Fifth Circuit
Judge
Catharina Haynes (George W. Bush, 2008); James E. Graves Jr. (Barack Obama, 2011); Irma Carrillo Ramirez (Joe Biden, 2023)
Date Decided
September 28, 2026
Docket No.
26-30081
Topics
Civil Rights; Excessive Force; Summary Judgment; Evidence
Source
Read the full opinion

Background

Brandon Stevenson, a Louisiana prisoner, filed a civil-rights complaint alleging that Lonnie Nail used excessive force against him. The district court entered summary judgment for Nail and dismissed Stevenson’s complaint with prejudice.

On appeal, Stevenson challenged both the district court’s definition of the summary-judgment record and its merits ruling. His evidentiary arguments concerned the exclusion of an original written statement from his cellmate and the denial of Stevenson’s motion to supplement the record.

The Court’s Holding

The Fifth Circuit held that the district court did not abuse its discretion by determining that the cellmate’s original written statement was not competent summary-judgment evidence. The court also concluded that denying Stevenson’s motion to supplement the record was a discretionary ruling and was not an abuse of that discretion.

Reviewing the merits de novo based on the record established by those evidentiary rulings, the court held that Stevenson had not shown error in the grant of summary judgment to Nail. It therefore affirmed the dismissal of the complaint with prejudice.

Key Takeaways

  • A written witness statement must satisfy the requirements for competent summary-judgment evidence.
  • The district court acted within its discretion in excluding the cellmate’s original statement and declining to supplement the record.
  • On the properly defined record, Stevenson failed to demonstrate error in the summary-judgment ruling for Nail.

Why It Matters

The decision underscores that evidentiary compliance at the summary-judgment stage can determine the record on which an excessive-force claim is evaluated. A party cannot rely on a witness statement that fails to qualify as competent evidence under the applicable procedural requirements.

It also illustrates the different standards of review governing such appeals: evidentiary and record-supplementation rulings receive abuse-of-discretion review, while the resulting summary-judgment decision receives de novo review.

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