A Sullivan & Cromwell lawyer apologized to a bankruptcy judge for filing documents with incorrect case citations caused by artificial intelligence.
The firm didn’t properly review legal citations, Andrew Dietderich, co-chair of the firm’s restructuring practice, told the judge. Sullivan & Cromwell didn’t follow its protocols and is “evaluating whether further enhancements to its internal training and review processes are warranted,” he said.
The apology April 18 followed the filing of the error-ridden documents 10 days earlier in the Southern District of New York’s bankruptcy court before Judge Martin Glenn. A spokesperson for Sullivan & Cromwell declined to comment.
AI hallucinations have increasingly been showing up in filings in US courts, prompting judges in some cases to fine lawyers responsible for the errors. A database tracking such filings has more than 330 examples.
In the case with the errant filing, Sullivan & Cromwell represents the liquidators of Prince Global Holdings Ltd., a group of British Virgin Islands entities. The Justice Department indicted Prince Global’s owner, Chen Zhi, in October for allegedly running an internet scam compound in Cambodia.
The Wall Street law firm’s errant documents appeared to cite the wrong or fake cases and numbers and inaccurate titles of articles. Sullivan & Cromwell’s April 18 filing included a red-line version of the earlier document correcting the errors, which in some cases involved the fixing of entire sentences.
Firm “safeguards are designed to prevent exactly this situation,” Dietderich wrote in the new filing. “Regrettably, this review process did not identify the inaccurate citations generated by AI, nor did it identify other errors that appear to have resulted in whole or in part from manual error.”
Dietderich said he also apologized to lawyers at Boies Schiller Flexner who alerted him to the errors. Matthew Schwartz, Boies Schiller’s chair, is counsel to Chen, according to a court document.
A hearing in the case is scheduled for Wednesday. The corrected filing is at the top of the agenda.
The case is: Prince Global Holdings Limited and Paul Pretlove, Bankr. S.D.N.Y., 1:26-bk-10769, 4/18/26.
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