Full Opinion

Cite as 2026 Ark. 127 SUPREME COURT OF ARKANSAS No. CV-26-356 Opinion Delivered: October 1, 2026 ANDREW SIMPSON PETITIONER APPEAL FROM THE ASHLEY COUNTY CIRCUIT COURT; PROBATE DIVISION V. [NO. 02PR-24-27] HONORABLE ROBERT BYNUM LARRY PORTER AND GIBSON III, JUDGE TERESA PORTER RESPONDENTS ORDER TO SHOW CAUSE. PER CURIAM While reviewing the petition in this case, the court discovered a citation to what appears to be a nonexistent case. On page 8 of the pro se petition for writ of mandamus, the petitioner, Andrew Simpson, cited Biscoe v. Williams, 373 Ark. 336 (2008), for the proposition that orders are void when a party commits fraud upon the court. However, no legal databases return any results for an Arkansas case titled Biscoe v. Williams, and the given citation leads to the middle of an unrelated case, Brown v. Brown, 373 Ark. 333, 284 S.W.3d 17 (2008). Because Biscoe v. Williams does not appear to exist, the court is concerned that this citation was hallucinated by artificial intelligence. When someone appears pro se before this court (or any court in the state), he is “held to the same standards as licensed attorneys with respect to complying with the rules.” Lucas v. Jones, 2012 Ark. 365, at 8, 423 S.W.3d 580, 585. Accordingly, pro se litigants must make arguments that are “warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law.” Ark. R. App. P. –Civ. 11(a). Relying on nonexistent authority is a dereliction of that duty. Ark. Dep’t of Hum. Servs. v. Ward, 2026 Ark. 17, at 2, 728 S.W.3d 373, 374. Therefore, Mr. Simpson is ordered to respond to this order and provide a copy of Biscoe v. Williams, if it exists. If the case does not exist, Mr. Simpson is ordered to explain how he learned of Biscoe v. Williams, why he decided to cite it, and to provide good cause for why he should not be sanctioned for citing authority that does not appear to exist. The response to this order must be filed no later than 4:00pm on Thursday, October 15, 2026. It is so ordered. Special Justice CORY COX joins. WOOD, J., concurs. WEBB, J., not participating. 2