system. See, e.g., Farm Bureau Policyholders & Members v. Farm Bureau Mut. Ins. Go., 330 Ark. 350, 952 S.W.2d 675, 676 (1997). Gates argues that the de facto judge doctrine does not apply to pro tempore judges. However, several cases have held that the doctrine applies to judges pro tem-pore. See, e.g., Survance v. State, 465 N.E.2d 1076, 1081-82 (Ind.1984); Giles v. State ex rel. Giles, 191 Tenn. 538, 235 S.W.2d 24, 29 (1950); Mattingly v. Commonwealth, 310 Ky. 561, 221 S.W.2d 82, 84 (1949). We agree -with these cases, because the policy considerations previously discussed apply with equal force to judges pro tempore. In addition, just as with regularly appointed judges, judges pro tempore act under color of authority. See State v. Hill, 17 Wash.App. 678, 564 P.2d 841, 843 n. 1 (1977) (<HOLDING>); see also Pickens v. Johnson, 42 Cal.2d 399,
holding that where a judge pro tempore is in actual possession of the office and discharging its duties he or she acts under color of title and is a judge de facto recognizing that a prosecutors office is an entity and that information in the possession of one attorney in the office must be attributed to the office as a whole holding that the appointment of a pro tempore judge vests in him or her the powers of a judge of the   court during the period specified in the assignment recognizing that judge who continued to function after end of term was a de facto judge whose actions could not be collaterally attacked holding that when a judicial office is created by legislative act or municipal ordinance  the office is regarded as a de facto office until the act or ordinance is declared invalid