Marialexa Natsis, The Balancing of Executive Emergency Powers As They Relate to the Pandemic and Eviction Control, 18 Hastings Bus. L.J. 213 (2022), Marialexa Natsis discusses California governor Gavin Newsome’s use of executive power to implement an eviction moratorium, including how challenges to similar uses of executive power were decided in other states. She discusses Friends of Danny Devito v. Wolf, noting that the Supreme Court of Pennsylvania found that Governor Wolf’s use of executive orders was neither unduly oppressive nor a violation of the separation of powers, and the temporary order was not a Taking under the state constitution. She concludes that the similarities between the executive orders in Pennsylvania and California likely mean the California governor’s orders are constitutional as well.