Courts on AI / Fabricated or misquoted citations
Hrdlichka v. Bengtson
Arkansas Court of Appeals · State appellate courts · AR · · 2026 Ark. App. 205; 2026 WL 886645 · No. No. CV-25-106 · opinion
On 2026-04-01, Arkansas Court of Appeals dismissed the appeal because the self-represented appellant’s brief was noncompliant and relied on fictitious authorities that prevented meaningful review. A self-represented party submitted an appellate brief with multiple fabricated or nonexistent authorities. The court resolved the merits while identifying the defective legal research.
- Disposition
- The court dismissed Hrdlichka’s appeal for fatal briefing deficiencies, including fictitious citations.
- Recorded conduct
- Hrdlichka’s pro se appellate brief cited multiple fictitious cases that were not found in Arkansas Reports, the South Western Reporter, or recognized legal databases, and it failed Rule 4-2 formatting requirements. — outcome: dismissal; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
mischaracterized. Fabricated citations—whether cites multiple cases that, upon review, do not exist. The created intentionally or through unverified use of artificial authorities relied on in support of his arguments are not found intelligence—waste judicial resources, delay resolution of in the Arkansas Reports, the South Western Reporter, or cases, and erode confidence in the judicial system. any recognized legal database. In short, they are fictitious. We cannot evaluate arguments predicated on nonexistent Second, all litigants, including pro se appellants, bear precedent. The appellate process depends on accurate citation responsibility for the contents of their filings. The use to existing authority so that we may assess the legal of artificial intelligence does not relieve a litigant of the foundation of a party's claims. When a party cites fabricated duty to verify the accuracy of citations. A brief containing cases, we are deprived of any meaningful ability to conduct nonexistent cases is no different, in effect, from a brief review. Fictitious citations fail to comply with Rule 4-2 of containing invented precedent. the Rules of the Arkansas Supreme Court and Appellate Court. Rule 4-2(a)(7) requires that arguments contain citation Third, the court emphasizes
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