Incident Tracker / United States (state)
Hrdlichka v. Bengtson
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.
- Court
- Arkansas Court of Appeals
- Date
- 2026-04-01
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- 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
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-08
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)2026-10-07 · Court of Appeals of Iowa · DismissalIn the Court of Appeals of Iowa, a self-represented appellant's final brief in a protective-order appeal contained multiple hallucinated case citations. After two earlier briefs were struck and the appellant failed to a…
- Washington v. Justice, No. 2D2025-2678 (Fla. 2d DCA 2026)2026-10-07 · District Court of Appeal of Florida, Second District · DismissalIn Florida's Second District Court of Appeal, self-represented appellants filed a brief citing eleven cases the court could not find and likely generated by AI. After an unavailing show-cause response and a pattern of f…
- Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-5462026-10-02 · Nebraska Supreme Court · Filing struckIn Nebraska, the state Supreme Court struck a self-represented divorce litigant's appellate brief for fictitious citations produced by his admitted AI use. Extending Prososki v. Regan to unrepresented parties, it held s…
- R. M. v. Mohr, 353 Or App 182 (2026), A1880922026-09-23 · Oregon Court of Appeals · FineIn Oregon, the Court of Appeals ordered a self-represented restraining-order appellant to pay $250 after his brief cited three fabricated cases he admitted came from AI. The court had threatened $1,500, at $500 per fake…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Hrdlichka v. Bengtson”, safelegalai.com/tracker/patrick-hrdlichka-v-samantha-bengston (accessed 2026-10-07). Data: CC BY 4.0.