Sullivan & Cromwell Apologizes for AI-Generated Errors in Legal Filing, Promises Stronger Review Protocols

April 21, 2026
Sullivan & Cromwell Apologizes for AI-Generated Errors in Legal Filing, Promises Stronger Review Protocols
  • Sullivan & Cromwell apologized to a U.S. Bankruptcy Court chief judge for a filing that relied on inaccurate AI-generated citations and other errors, signaling accountability at the highest level.

  • Andrew Dietderich, co-chair of the firm’s restructuring practice, told the judge that the firm did not follow its review protocols and is considering strengthening training and internal review processes.

  • Two related notes: potential departures of S&C partners Jeffrey Wall and Morgan Ratner for Gibson Dunn, and Damien Charlotin’s tally of AI hallucinations surpassing 1,300 cases.

  • Dietderich stressed the firm’s comprehensive AI policies and safeguards, but acknowledged these measures failed to prevent hallucinations and citation inaccuracies.

  • The reporting references tools like BriefCatch’s RealityCheck and situates the incident within an ongoing debate over AI governance in legal practice.

  • AI hallucinations in legal work—fabricated citations, misquotations, and non-existent sources—have been rising since 2023, according to researchers tracking the trend.

  • The correspondence argues that AI in legal workflows requires meticulous human review, including line-by-line verification and printed checks.

  • The issue is framed as systemic across Am Law 100 firms, with calls for rigorous manual verification rather than overreliance on automated checks.

  • This incident reflects broader scrutiny of AI in legal research and drafting, where judges have sanctioned lawyers for AI-related inaccuracies, though AI use is not banned if accuracy is ensured.

  • Lawyers may use AI, but they have an ethical duty to ensure submission accuracy, with past sanctions serving as a reminder of that obligation.

  • The pattern of sanctions in AI-related cases underscores the need for thorough vetting of AI outputs in filings.

  • The piece compares this incident to previous AI failures and notes tools like RealityCheck as safeguards against hallucinations in briefs.

Summary based on 13 sources


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