Appellate Division, Second Department · October 7, 2026 · 2026 NY Slip Op 05822
Shapiro v Kushnick-Carr
Read the official decision: 2026 NY Slip Op 05822
Holding The court held that the plaintiff’s defamation claim lacked a substantial basis in law because the defendant’s Google review constituted nonactionable pure opinion rather than factual assertion. Consequently, the action was deemed a SLAPP suit, warranting dismissal and an award of attorneys’ fees to the defendant.
The court’s words
the defendant's statements in her Google review of the plaintiff and his law firm unmistakably constitute nonactionable pure opinion
2026 NY Slip Op 05822, at the official text
The phrase, "tinker of many types of law, a master of none," is a variation of the familiar idiom, "jack of all trades, master of none," a figure of speech that is subjective and imprecise on its face
2026 NY Slip Op 05822, at the official text
the context in which the review appeared signals to readers that the statement is likely to be opinion, not fact
2026 NY Slip Op 05822, at the official text
| Court | Appellate Division, Second Department |
|---|---|
| Decided | October 7, 2026 |
| Citation | 2026 NY Slip Op 05822 |
| Area of law | Defamation and Anti-SLAPP |
| Week | Week ending October 10, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05822 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 1045 |
Recommended citation
ESQ HQ, New York Law Watch, Shapiro v Kushnick-Carr, 2026 NY Slip Op 05822 (Appellate Division, Second Department, October 7, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05822/
How this record was made
Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.
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