What is a “Yellowstone injunction”? No, it's not related to the National Park. Since the New York Court of Appeals landmark decision in First National Stores Inc. v. Yellowstone Shopping Center, Inc., commercial tenants have had a powerful tool to delay termination of their commercial leases for alleged violations. However, a recent decision from the New York Court of Appeals (New York’s highest court) affirmed a ruling that a waiver of the tenant-friendly Yellowstone injunction does not violate public policy.