Simpson v Porter
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Simpson v. Porter is an Arkansas Supreme Court mandamus proceeding arising from a probate matter. On October 1, 2026, the court ordered petitioner Andrew Simpson to explain a citation to an apparently nonexistent case. The court expressed concern that the citation might have been hallucinated by artificial intelligence; the order makes no finding that Simpson used AI.[1]
October 1 order
Simpson's pro se petition cited Biscoe v. Williams, 373 Ark. 336 (2008), for a proposition about fraud upon the court. The Supreme Court reported that legal databases showed no Arkansas case with that title and that the citation pointed into an unrelated decision, Brown v. Brown. It said pro se litigants must meet the same court-rule standards as attorneys and that reliance on nonexistent authority would breach that duty.[1]
The court directed Simpson to provide a copy of Biscoe if it exists. Otherwise, he must explain how he learned of the purported case, why he cited it, and why he should not be sanctioned. The response is due October 15, 2026, at 4 p.m. The order does not decide the merits of the mandamus petition or impose a sanction.[1]