Sullivan & Cromwell, one of the nations leading corporate law firms, has formally apologized to the U.S. Bankruptcy Court in Manhattan after acknowledging that a filing contained inaccurate citations and other errors generated by artificial intelligence. The apology, sent in a letter dated April 18, was addressed to Martin Glenn, chief judge of the court.
In the letter, Andrew Dietderich, co-head of the firms global restructuring group, said the mistakes included what he described as AI "hallucinations" - instances where the technology produced invented case citations, misquoted legal authority, or cited non-existent sources. Dietderich wrote that the errors were identified by opposing counsel in the matter, the law firm Boies Schiller Flexner, and that he had contacted that firm to thank them and apologize directly.
"I apologize on behalf of our entire team. I also called Boies Schiller Flexner LLP on Friday to thank them for bringing this matter to our attention and to apologize directly to them as well," Dietderich wrote.
The letter does not disclose which AI program was used to assist in producing the filing. Dietderich and a representative of Sullivan & Cromwell did not immediately respond to requests for comment, according to the correspondence.
Sullivan & Cromwell told the judge that it maintains "comprehensive policies and training requirements governing the use of AI tools in legal work" intended to reduce the risk of such mistakes. However, the letter made clear that those established policies were not followed in this instance, and that the secondary review process also failed to detect the inaccurate citations generated by the AI. The firm subsequently filed a corrected version of the submission.
The episode comes amid growing judicial scrutiny of attorneys use of artificial intelligence. The letter noted that U.S. judges have sanctioned lawyers in dozens of cases after attorneys relied on AI for legal research and drafting without sufficiently verifying the outputs. While the use of AI by lawyers is not expressly prohibited, attorneys remain ethically obligated to ensure the accuracy of documents submitted to courts.
Sullivan & Cromwell, headquartered in New York and employing more than 900 lawyers, is widely regarded for its work in mergers and acquisitions, corporate governance litigation and private equity. In the New York case at issue, the firm represents foreign representatives involved in the wind-down of Prince Global Holdings Limited, a Cambodian conglomerate.
Prince Globals founder and chairman, Chen Zhi, has been charged in Brooklyn federal court with allegedly directing forced labor compounds in Cambodia and with orchestrating a large-scale investment fraud, according to the court matter. Prince Group previously issued a statement denying wrongdoing and calling the allegations baseless. The groups representative could not be immediately reached for comment in connection with the filing error.
Boies Schiller Flexner is representing a group of objecting debtors in the bankruptcy proceedings. A Boies Schiller attorney involved in the case did not immediately respond to a request for comment regarding the identification of the AI-generated errors.
The Sullivan & Cromwell incident underscores persistent challenges firms face as they integrate AI tools into legal workflows - including ensuring compliance with internal policies and conducting thorough human review to catch fabrications or misstatements produced by automated systems.