In March 2020, as New York City became the epicenter of the COVID-19 pandemic, Governor Andrew Cuomo issued a number of executive orders, some of which required non-essential businesses to
Guaranty Law Invalidated
Consistent with the Second Circuit's opinion, the District Court in March 2023 found that the Guaranty Law, a pandemic law that was implemented to protect struggling commercial tenants and small businesses, lacked the requisite reasonability to overcome a Contract Clause challenge,

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