On April 14, 2026, the Appellate Division, First Department issued a decision in which it reiterated the limits of fraud claims in the corporate governance context. In Massoumi v. Ganju, 2026 N.Y. Slip Op. 02208 (1st Dept. Apr. 14, 2026), the Court unanimously affirmed summary judgment dismissing fraud claims brought by a former chief executive officer who alleged that his fellow executives and directors misled him in advance of a board meeting that resulted in his removal.

In today’s article, we examine the elements and heightened pleading requirements for fraudulent inducement claims under New York law, with a focus on the justifiable reliance element.

In today’s Fraud Notes, we examine Yudkin v. Evergreen Terrace 888 Corp., 2025 NY Slip Op 03223 (2d Dept. May 28, 2025), and Lapin v. Verner, 2025 NY Slip Op 03184 (2d Dept. May 28, 2025). Yudkin involved the statute of limitations for fraud and the continuing wrong doctrine. Lapin involved the failure to plead the elements of a fraud claim.