Patrick Hrdlichka v. Samantha Bengston
CA Arkansas · Apr 1, 2026
- Jurisdiction
- state
- Court
- CA Arkansas
- Record ID
- patrick-hrdlichka-v-samantha-bengston-2026-04-01
- Observed outcome
- The appeal was dismissed due to pervasive briefing deficiencies and the inclusion of fictitious legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Arkansas Court of Appeals dismissed the appellant's brief and appeal after finding that the pro se litigant submitted a brief containing multiple fabricated legal citations, which the court attributed to the unverified use of artificial intelligence tools.
The court reasoned that the appellant's reliance on fictitious cases prevented meaningful appellate review, violated Rule 4-2 of the Rules of the Arkansas Supreme Court and Court of Appeals, and constituted an abuse of the adversary system that wasted judicial resources.
This case illustrates the judiciary's intolerance for AI-generated hallucinations in appellate filings. It reinforces that pro se litigants are held to the same standards of accuracy and verification as licensed attorneys, and that fabricated citations will result in the dismissal of appeals.
Failure modes and consequences
- Pro Se
- Fake Citations
- Tort
- Appellate
- Warning
- AI attribution
- Implied
- Recorded tool
- artificial-intelligence tools
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a civil bench trial judgment; the court dismissed the appeal due to fatal briefing deficiencies.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court identified the use of artificial-intelligence tools.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all legal citations, regardless of the research method used.
- Ensure that all filings are reviewed for compliance with local appellate rules regarding citation format and authority existence.
- Establish internal policies requiring human verification of any legal research or drafting assisted by generative AI.