Espinoza v. M&R Construction Group Inc.

What is the current procedural posture?

The court granted plaintiff summary judgment on his Labor Law § 240 (1) and § 241 (6) claims, denied defendants' cross-motion (including the Labor Law § 200 branch, as untimely), and rejected Shorewood's argument that it was not a proper Labor Law defendant. On the citation, it wrote: "In light of this apparently fabricated caselaw, a sanctions hearing will be scheduled in the decretal section of this decision." The decretal paragraph states: "A sanctions hearing is scheduled for April 10, 2026 at 10:00am." The decision imposes no sanction itself and does not identify whom the hearing concerns beyond the moving papers that contained the citation. No decision on the sanctions hearing appears in the New York Law Reporting Bureau's slip-opinion archive as of September 30, 2026, so the entry is marked pending; the outcome of the April 10 hearing is not known from any source read.

Why does Espinoza v. M&R Construction Group Inc. matter for law firms using AI?

Espinoza is a Labor Law summary judgment decision in which the court addressed a nonexistent authority in the course of rejecting one defendant’s argument. Shorewood contended it was not a proper Labor Law defendant because it lacked authority to supervise the work. The court rejected that on the record, citing the construction management agreement’s designation of Shorewood as an owner entity and testimony that Shorewood was the owner’s representative. It then turned to the authority Shorewood had relied on.

The court’s treatment of the citation is short and specific. Shorewood cited “Parrelli v. Temple Beth El of Great Neck, 304 A.D.2d 788, 789 [2d Dept 2003].” Plaintiff’s counsel had noted that the case does not exist, and the court agreed after its own search: it found no case with that caption, identified the closest Second Department case (Berger v Temple Beth El of Great Neck, a defamation action) as having nothing to do with the dispute, and found that the reporter citation pointed into a Westchester land-use declaratory judgment decision. The decision does not mention artificial intelligence; its description is “apparently fabricated caselaw.”

Rather than resolve the issue on the papers, the court scheduled a sanctions hearing for April 10, 2026. No decision following that hearing was located in the Law Reporting Bureau’s archive, so the entry is pending and its outcome unknown. Firms documenting compliance may wish to consider that, here, a single nonexistent citation in summary judgment papers led the court to set a sanctions hearing in the same decision that granted the opposing party summary judgment.