'Yellowstone' Update: When Courts Deny Relief

In their Landlord-Tenant column, Warren A. Estis and Michael E. Feinstein, partners at Rosenberg & Estis, write: Because the tenant's burden on a motion for a 'Yellowstone' injunction is far less than what must be shown on a motion for a "normal" preliminary injunction, it is not surprising that motions for 'Yellowstone' relief are routinely granted. On this 45th anniversary of 'Yellowstone,' however, we thought it time to examine some recent decisions in which courts have denied Yellowstone relief in certain circumstances.

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