On December 16, 2020, Judge Denise Cote of the United States District Court for the Southern District of New York dismissed an art dealer’s breach of contract action alleging that the defendant auction house had improperly terminated the parties’ agreement.  JN Contemporary Art LLC v. Phillips Auctioneers LLC, – F. Supp. 3d – , 2020 WL 7405262 (S.D.N.Y. Dec. 16, 2020).  Plaintiff contended that the auction house was not permitted to terminate the parties’ contract because the pandemic did not constitute a “natural disaster” within the meaning of the agreement’s force majeure clause.  The Court held, applying New York law, that the COVID-19 pandemic is a “natural disaster” and therefore dismissed the action.