Patrick Hrdlichka v. Samantha Bengston
Court of Appeals of Arkansas · Ark. Ct. App. · Arkansas bar guidance
Verified May 14, 2026
- Citation
- Hrdlichka v. Bengston, 2026 Ark. App. 205 (Ark. Ct. App. Apr. 1, 2026) (Barrett, J.)
- Decided
- April 1, 2026
Summary
Patrick Hrdlichka, proceeding pro se, appealed a Benton County Circuit Court judgment that awarded Samantha Bengston $10,000 in compensatory damages on a battery claim. The Court of Appeals of Arkansas, in an opinion by Judge Stephanie Potter Barrett, found his brief deficient in several respects, including citations to cases that do not appear in any recognized legal database. "In short, they are fictitious," the court wrote. The fictitious citations failed to comply with Arkansas Supreme Court Rule 4-2, which governs the content of appellate briefs.
- AI tool:
- Unidentified (the court found the brief cited 'fictitious' cases not in any legal database; no AI tool named in the opinion)
What sanction did the court impose?
The court dismissed the appeal. It held that the briefing deficiencies, including the fictitious citations, violated Rule 4-2, and that the rules "mandate dismissal of this appeal." The court imposed no separate monetary sanction; dismissal was the consequence.
Why does Patrick Hrdlichka v. Samantha Bengston matter for law firms using AI?
Hrdlichka v. Bengston shows an appellate court treating fabricated citations as a briefing defect that carries the same consequence as any other Rule 4-2 violation. Hrdlichka lost a $10,000 battery judgment in Benton County Circuit Court and appealed pro se. The Court of Appeals never reached his arguments. His brief failed to comply with Arkansas Supreme Court Rule 4-2 in several ways, and among the defects were citations to cases that do not exist in any legal database.
The court’s phrasing is worth noting. It did not run a Rule 11 analysis or open a sanctions inquiry. It folded the fictitious citations into the ordinary briefing-compliance review and held that the rules “mandate dismissal.” For a firm defending an appeal against a pro se litigant in Arkansas, the practical read is that fabricated authority in an opening brief does not need a separate sanctions motion to matter. It is a Rule 4-2 deficiency, and Rule 4-2 deficiencies get appeals dismissed.