The Brief That Cited Ghosts
Friday, April 24, 2026
Photo by COPPERTIST WU / Unsplash
Sullivan & Cromwell submitted fabricated legal citations generated by AI. The firm advises OpenAI on the safe and ethical use of the same technology.
What's happening
Sullivan & Cromwell, a 140-year-old Wall Street law firm with more than 1,000 attorneys, has apologized to a federal bankruptcy judge after a court filing in the Prince Global Holdings case contained fabricated case citations, incorrect case names, and invented quotations, all generated by artificial intelligence. The errors were caught by opposing counsel at Boies Schiller Flexner. The firm's restructuring group leader acknowledged that internal AI safeguard policies were not followed, and the errors also bypassed the firm's citation review process. The incident carries a specific irony: Sullivan & Cromwell represents OpenAI and promotes on its website its role advising the company on "safe and ethical deployment" of artificial intelligence. The filing joins a growing list of AI-generated legal fabrications since Mata v. Avianca in 2023, when a New York attorney first submitted ChatGPT-generated citations to a federal court.
What the Text says
Jeremiah confronted a professional class that had positioned itself as the custodian of authoritative text.
Jeremiah 8:8How do you say, We are wise, and the law of Yahweh is with us? But, behold, the false pen of the scribes has worked falsely.
The scribes were the legal scholars of ancient Israel, the people whose work was to copy, interpret, and transmit the law with precision. Their authority depended entirely on the reliability of what they produced. When Jeremiah accuses them of wielding a "false pen," he describes something more dangerous than an individual lie. He describes a corruption at the source. If the scribes' pen is false, then every document it produces is contaminated, and the people who trust those documents have no way of knowing.
The Sullivan & Cromwell filing is a contemporary version of this failure. The cases cited did not exist. The quotes attributed to judges were never spoken. The system that was supposed to verify these citations failed to catch the fabrication. The firm's own safeguards were bypassed. And the firm's claim to expertise in AI safety makes the failure recursive: the institution that promises to govern the tool was governed by the tool instead. Jeremiah's critique was never about one dishonest scribe. It was about what happens to a system of law when the instruments of authority can no longer be trusted.
The reflection
The legal system runs on citation. Every argument rests on the authority of what came before. When that chain is broken by fabrication, the damage reaches the foundation: the assumption that what a lawyer presents to a court has been verified by a human mind against a real record. Sullivan & Cromwell's apology acknowledged a process failure. Jeremiah would have recognized something older. The scribes did not set out to deceive. They trusted an instrument they had not tested. The false pen does its best work in confident hands.
