In re Prince Global Holdings Limited, et al.
U.S. Bankruptcy Court, Southern District of New York · Bankr. S.D.N.Y. · New York bar guidance
Verified September 28, 2026
- Citation
- In re Prince Global Holdings Ltd., No. 26-10769 (MG), Letter of A. Dietderich, ECF No. 25 (Bankr. S.D.N.Y. Apr. 18, 2026)
- Decided
- April 18, 2026
Summary
Sullivan & Cromwell LLP, representing the Joint Provisional Liquidators in a Chapter 15 cross-border insolvency proceeding, self-reported to Chief Bankruptcy Judge Martin Glenn that its April 9, 2026 "Emergency Motion for Entry of Orders Granting (I) Ex Parte Relief and (II) Provisional Relief" (D.I. 9) included inaccurate citations and other errors, including AI "hallucinations." Andrew G. Dietderich signed the disclosure letter, whose Schedule A identifies and corrects inaccurate pin cites, reporter numbers, and quotations of authorities including In re Three Arrows Capital, Ltd., In re Soundview Elite Ltd., In re BYJU's Alpha, Inc., and In re Team Systems International, LLC. The letter does not identify any cited case as nonexistent. The Firm acknowledged that its policies on the use of AI, which require independent verification of AI output, were not followed, and that its citation review did not identify the inaccurate citations generated by AI.
- AI tool:
- Unspecified generative AI
How did the court address the AI-related conduct?
No court-imposed sanction. The Firm disclosed the errors after Boies Schiller Flexner LLP brought them to its attention, filed a corrected motion with a redline that day (ECF No. 27), and apologized to the Court and to Boies Schiller. Dietderich accepted responsibility, referring to the duty of accuracy under Local Bankruptcy Rule 9011-1(d), and stated the Firm was evaluating whether further enhancements to its internal training and review processes are warranted. The CourtListener docket, checked on 2026-09-28, shows no court order, show-cause order, or sanction addressing the errors.
Why does In re Prince Global Holdings Limited, et al. matter for law firms using AI?
Prince Global is notable because the disclosing firm, Sullivan & Cromwell, describes mandatory AI training and a written policy requiring lawyers to “independently check all answers, case citations, and other information or work product received from an AI Program for both substantive and non-substantive accuracy.” The letter to Chief Judge Glenn concedes that the Firm’s AI policies “were not followed” on an emergency motion and that its citation review “did not identify the inaccurate citations generated by AI.” For managing partners at smaller firms, the letter illustrates that written AI policies and mandatory training did not prevent the errors here; firms documenting compliance may wish to consider how a verification step is confirmed on each filing, and how quickly errors are disclosed once another party flags them.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.