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At the onset of the coronavirus (COVID-19) pandemic, four Pennsylvania businesses challenged Governor Tom Wolf’s statutory authority to close non-essential (or non-life sustaining) businesses to mitigate the public health effects of the pandemic. In that case, 
Friends of Danny Devito v. Wolf, 227 A.3d 872 (Pa. 2020), the petitioners argued Governor Wolf lacked the statutory authority under the Pennsylvania Emergency Management Services Code to issue an executive order mandating the temporary closure of inessential businesses. The Pennsylvania Supreme Court disagreed and recognized that the COVID-19 pandemic qualified as a natural disaster under the Pennsylvania Emergency Code, 35 Pa.C.S.A. § 7102. Section 7102, which defines “natural disaster” as any “catastrophe which results in substantial … hardship, suffering or possible loss of life. The  ....

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