An expression of pure opinion is not actionable, no matter how vituperative or unreasonable it is. In determining whether a statement is pure opinion, the court will consider (1) whether the specific language has a precise meaning that is readily understood; (2) whether the statement is capable of being proven true or false; and (3) whether, in context, the reader or listener would understand that the statement is an expression of opinion, not fact.
Trump Vil. Section 4, Inc. v. Bezvoleva, NY Slip Op 03389 (2d Dep't May 9, 2018)
Here is the decision.