Yellowstone injunctions have long constituted important protection for commercial tenants in New York. Originating with the 1968 Court of Appeals decision in First Nat'l Stores v. Yellowstone Shopping Ctr,
<b><i>Is This The End of the 'Yellowstone' Doctrine?</b></i><p>Recently, New York's Appellate Division, Second Department, acknowledged that commercial landlords may employ a strategy that prevents tenants from exercising Yellowstone rights, which enjoin the landlord from terminating the lease or commencing a summary proceeding.

Yellowstone injunctions have long constituted important protection for commercial tenants in New York. Originating with the 1968 Court of Appeals decision in First Nat'l Stores v. Yellowstone Shopping Ctr,
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