Nolan v. Buchanan
CourtCourt of Appeals for the Fifth Circuit
Date FiledNovember 10, 2026
Docket25-30724
StatusUnpublished
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Full Opinion
Case: 25-30724 Document: 64-1 Page: 1 Date Filed: 11/10/2026
United States Court of Appeals
for the Fifth Circuit
United States Court of Appeals
Fifth Circuit
____________ FILED
November 10, 2026
No. 25-30724 Thomas B. Plunkett, III
Summary Calendar Clerk
____________
Antonio Lashun Nolan,
Plaintiff—Appellant,
versus
Jared Buchanan, Officer, In His Individual Capacity; Zane
Crittenden, Officer, In His Individual Capacity; Luke Price, Officer,
In His Individual Capacity; Police Department of Minden;
Jimbo Yocom,
Defendants—Appellees.
______________________________
Appeal from the United States District Court
for the Western District of Louisiana
USDC No. 5:25-CV-1144
______________________________
Before Willett, Duncan, and Engelhardt, Circuit Judges.
Per Curiam: *
Antonio Lashun Nolan appeals the dismissal of his 42 U.S.C. § 1983
suit as frivolous and for failure to state a claim. See 28 U.S.C. § 1915(e)(2)(B).
We AFFIRM the district court’s judgment and DENY Nolan’s motions
_____________________
*
This opinion is not designated for publication. See 5th Cir. R. 47.5.
Case: 25-30724 Document: 64-1 Page: 2 Date Filed: 11/10/2026
No. 25-30724
seeking a limited remand for the purpose of clerical or administrative
corrections under Rule 60(a) or direct correction of the record.
Nolan’s substantial compliance with the magistrate judge’s order to
amend his complaint did not preclude dismissal. By directing Nolan to
answer specific questions, the magistrate judge effectively used a
questionnaire, which is “a useful means by which the court can develop the
factual basis for [a] complaint.” Watson v. Ault, 525 F.2d 886, 892 (5th Cir.
1976). Mere compliance with a questionnaire, however, does not establish
factual sufficiency. See id. Nor did the magistrate judge violate Nolan’s due-
process rights by instructing him not to repeat allegations from his earlier
pleadings. The report and recommendation, which the district court
adopted, expressly considered those pleadings.
Nolan also has not shown that the district court erred in concluding
that the Heck favorable-termination rule bars his claims. See Heck v.
Humphrey, 512 U.S. 477, 487 (1994). We have explained that when an
“unlawful-arrest claim plainly arises from the same facts as [a] resisting-
arrest conviction,” permitting recovery under § 1983 “for unlawful arrest
would necessarily imply that any conviction for resisting the arrest was
invalid.” Johnson v. Thibodaux City, 887 F.3d 726, 732 (5th Cir. 2018). None
of Nolan’s cited cases undermines that rule.
Finally, Nolan has not explained how the classification of his case
affected the screening of his complaint under § 1915(e)(2). We therefore see
no basis for reversal or a limited remand to correct the alleged coding errors.
Nolan has not demonstrated any substantive or procedural error in the
district court’s dismissal of his claims. Any other challenge is forfeited. See
Yohey v. Collins, 985 F.2d 222, 224–25 (5th Cir. 1993). Accordingly, the
district court’s judgment is AFFIRMED. Nolan’s motions concerning the
caption and coding of his case are DENIED.
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