In Delgado v. 27-51 Jackson Ave. LLC, 2026 N.Y. Slip Op. 05593 (1st Dept. Oct. 1, 2026), the Appellate Division, First Department reaffirmed that fraud claims must be based on particularized facts, not suspicion, guilt by association, or allegations from other lawsuits. The Court held that unproven accusations in separate actions were insufficient to establish that the plaintiff made any misrepresentation.