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Sullivan & Cromwell Apologizes for AI-Generated Errors in Federal Court Filing

Apr 22, 2026 05:50 UTC
Short term

Major US law firm Sullivan & Cromwell has issued an apology after submitting a court motion containing approximately 40 AI-hallucinated citations. The incident underscores the ongoing risks of integrating generative AI into high-stakes legal workflows without strict oversight.

  • Approximately 40 fabricated citations found in emergency motion
  • Failure to adhere to internal AI oversight and review policies
  • Over 900 AI hallucination incidents recorded in US courts to date
  • Firm currently reviewing internal training and review protocols

Sullivan & Cromwell, one of the highest-revenue law firms in the United States, has formally apologized to the US Bankruptcy Court for the Southern District of New York after a court filing was found to contain numerous fabricated citations. The errors appeared in an emergency motion filed nine days prior to the apology. Andrew Dietderich, co-head of the firm's global restructuring team, admitted in a letter to Chief Judge Martin Glenn that the firm failed to ensure the accuracy of the submission. Dietderich noted that while Sullivan & Cromwell maintains specific AI policies designed to prevent incorrect citations and other errors, these procedures were not followed in this instance. The filing contained roughly 40 incorrect citations caused by AI hallucinations. The errors were brought to the firm's attention by a rival firm, Boies Schiller Flexner LLP, to whom Dietderich has since extended a direct apology. This incident reflects a broader trend of AI failures within the legal profession. According to data managed by legal technologist Damien Charlotin, there have been 1,334 recorded incidents of AI hallucinations in court filings worldwide, with more than 900 of those occurring in the US. While most involve fabricated citations, some cases have included entirely AI-generated legal arguments. Sullivan & Cromwell, which previously represented the crypto exchange FTX in its bankruptcy case, has initiated immediate remedial measures. The firm is currently conducting a full review of the circumstances leading to the errors and is evaluating whether to implement further enhancements to its internal training and review processes.

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