Patrick Hrdlichka v. Samantha Bengston

── Patrick Hrdlichka v. Samantha Bengston ── Court: Court of Appeals of Arkansas Date: April 01, 2026 Category: General Cite as 2026 Ark. App. 205 ARKANSAS COURT OF APPEALS DIVISION IV No. CV-25-106 PATRICK HRDLICHKA Opinion Delivered April 1, 2026 APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CV-23-3080] SAMANTHA BENGSTON HONORABLE JOHN R. SCOTT, APPELLEE JUDGE DISMISSED STEPHANIE POTTER BARRETT, Judge Patrick Hrdlichka, pro se, appeals from the Benton County Circuit Court order awarding appellee, Samantha Bengtson, $10,000.00 in compensatory damages as well as $237.50 in costs under Arkansas Code Annotated section 16-118-107 (Repl. 2016). On appeal, Hrdlichka argues (1) the circuit court incorrectly applied Arkansas Code Annotated section 16-118-107; (2) there was no evidence of felony conduct introduced, so he cannot be liable under Arkansas Code Annotated section 16-118-107; (3) compensatory damages were awarded without meeting the standard of preponderance of the evidence; (4) the circuit court’s interpretation of Arkansas Code Annotated section 16-118-107 contradicts well- established Arkansas jurisprudence; and (5) the court’s ruling violates his constitutional guarantee to equal protection under article 2, section 3 of the Arkansas Constitution. Bengtson did not file a response brief in this appeal. Due to numerous fatal briefing deficiencies under the Rules of the Supreme Court and Court of Appeals and Arkansas Rules of Appellate Procedure–Civil that prevent us from engaging in meaningful review, including the submission of fictitious cases, we dismiss the appeal. On November 7, 2023, Bengtson filed a complaint in the Benton County Circuit Court alleging that on the night of February 3, 2022, Hrdlichka committed a felonious second-degree battery against her, and she suffered damages as a result. Bengtson sought to recover damages under Arkansas Code Annotated section 16-118-107, which allows for crime victims to seek damages in a civil action. After a bench trial, the circuit court denied Bengtson’s request for punitive damages but awarded Bengtson $10,000.00 in compensatory damages plus interest at the rate of 5 percent until paid plus the cost of the service and filing fees. Hrdlichka did not object to the court’s award of damages. On November 1, 2024, the circuit court entered its written judgment awarding Bengtson $10,000.00 in compensatory damages and an additional $237.50 in costs. The standard of review on appeal from a bench trial is whether the court’s findings were clearly erroneous or clearly against the preponderance of the evidence. See, e.g., El Paso Prod. Co. v. Blanchard, 371 Ark. 634, 640, 269 S.W.3d 362, 368 (2008). A finding is clearly erroneous when, although there is evidence to support it, the reviewing court on the entire evidence is left with a firm conviction that an error has been made. Id. Facts in dispute and determinations of credibility are solely within the province of the fact-finder. Id. 2  The present appeal contains multiple fatal briefing deficiencies that prevent us from conducting a meaningful review. Parties appearing pro se, like Hrdlichka, receive no special consideration of their argument and are held to the same standard as licensed attorneys. See Perry v. State, 287 Ark. 384, 699 S.W.2d 739 (1985). Hrdlichka’s brief fails to comply with Rule 4-2 of the Rules of the Arkansas Supreme Court and Court of Appeals in numerous respects. Rule 4-2(a) prescribes the required contents and organization of an appellant’s brief, and the deficiencies here are p