Loeb Secures Preliminary Injunction Blocking Enforcement of New York Law Targeting Park Avenue Armory

Loeb & Loeb secured an important victory for the Seventh Regiment Armory Conservancy, Inc. (the Conservancy) in a closely watched constitutional challenge involving the historic Park Avenue Armory in Manhattan. On Nov. 25, 2025, Judge George B. Daniels of the U.S. District Court for the Southern District of New York issued a 26-page opinion granting the Conservancy’s motion for a preliminary injunction enjoining Empire State Development Corporation (ESD) from enforcing a recently enacted New York law that would permit ESD to designate portions of the Armory for the exclusive use of the Knickerbocker Greys (the Greys). 

The Conservancy, a not-for-profit organization that operates the Armory as a premier cultural venue for performing and visual arts under a 99-year lease with New York State, filed the action on Sept. 5, 2025, asserting that the law violates the U.S. Constitution, including the Contracts Clause, which prohibits States from passing laws “impairing the Obligation of Contracts.” Loeb argued that forcing the Conservancy to convey portions of its demised space under its lease to the Greys would interfere with the Conservancy’s protected contractual and property rights and disrupt ongoing artistic programming and operations at the landmark Armory.

Judge Daniels held that a preliminary injunction was warranted because “the Conservancy has shown that they are more likely than not to succeed on the merits of their Contracts Clause claim,” because it demonstrated, among other things, that designating portions of the Armory “for the exclusive use of the Greys would substantially impar the Conservancy’s contracted property rights under the lease.”

The decision represents a rare example of a federal court blocking enforcement of a state statute on U.S. constitutional grounds and is a strong proclamation that states may not interfere with private contracts.

The Loeb team representing the Conservancy is led by Litigation partner Joshua E. Hollander and includes Litigation senior counsel Katie Gauthier and Litigation associate Jacob M. Sievers.