On Dec. 27, 2021, all private employers in New York City are required to have their employees vaccinated. This mandate extends the requirement which had been imposed on City workers to private sector employees. Before it even took effect, the Governor's mandate order was immediately challenged in court. In the Western District of New York, the District Court issued an injunction against the enforcement of the mandate without opinion, 2021 WL 4734404, *8 (NDNY Oct. 12, 2021), while the Eastern District denied the request for a preliminary injunction. We the Patriots USA v. Hochul, No. 21-cv-4954 (EDNY Sept. 12, 2021). The Second Circuit affirmed the Eastern District and overruled the Western District decisions, 17 F.4th 368 (2d Cir. 2021) (per curiam).