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 April 26, 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 Provisional Relief contained AI-generated "hallucinations," including fabricated case citations and misquoted authorities. Partner Andrew G. Dietderich signed the disclosure letter, identifying inaccurate citations to In re Three Arrows Capital, Ltd. (struck entirely from paragraphs 27, 34, and 55), In re Soundview Elite Ltd., In re BYJU's Alpha, In re Team Systems International, and other authorities. The Firm acknowledged its written AI policies, which require independent verification of all AI output, were not followed.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No court-imposed sanction. The Firm voluntarily disclosed the errors after Boies Schiller Flexner LLP flagged them, filed a corrected motion with a redline that day, and apologized to the Court and to opposing counsel. Dietderich personally accepted responsibility under Local Bankruptcy Rule 9011-1(d) and stated the Firm was evaluating further enhancements to its internal training and review processes.
Why does In re Prince Global Holdings Limited, et al. matter for law firms using AI?
Prince Global is notable because the disclosing firm is Sullivan & Cromwell, an AmLaw top-tier firm with documented 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.” The letter to Chief Judge Glenn concedes the policy “was not followed” on a Chapter 15 emergency motion, and that the Firm’s standard citation review did not catch the fabrications. For managing partners at smaller firms, the case underscores that written AI policies and mandatory training are necessary but not sufficient: a verification step has to actually happen on every filing, and self-reporting opposing counsel’s discovery quickly is the standard professional response.
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.