Tom O'Neill and Melissa Bruynell Maness authored an article, "2 Rulings Instruct On Eviction Moratorium Constitutionality," published by Law 360. Many states and municipalities have put in place eviction moratoriums to assist tenants during the COVID-19 global pandemic, including an Act signed by the Governor of Massachusetts on April 20. Eviction moratoriums provide safeguards for residents and/or small-business tenants who have been affected financially by COVID-19. The Massachusetts eviction moratorium has come under fire after residential landlords filed an emergency petition in the matter of Matorin v. Sullivan, seeking to invalidate the Massachusetts eviction moratorium on the grounds that it allegedly violates the U.S. Constitution and Massachusetts Declaration of Rights. At this time, the court has not ruled on the tenants' petition, but other courts in different jurisdictions have ruled on similar emergency legislation and executive orders, which may be instructive as to how the court will rule in Matorin.