If any federal or state court rules that the pied-à-terre surcharge on non-primary residences in New York City, enacted by New York State in May 2026, violates the U.S. Constitution or the New York State Constitution, in whole or in part in a case challenging the constitutionality of that surcharge before Jan 1, 2028, then the market resolves to Yes. The ruling must: Be issued by any federal or state court in a case challenging the constitutionality of that surcharge, meaning the pied-à-terre surcharge Address the matter described by the specified judgment Be issued through a written order, opinion, judgment, or decision Partial relief counts. A written ruling that the surcharge is unconstitutional only in part, or only as applied to one or more plaintiffs, qualifies. A qualifying ruling counts when issued, even if it is later stayed, vacated, or reversed. The following do NOT satisfy the Payout Criterion: A ruling that rests only on statute, the city's rollout, tax notices, the supplemental tax roll, or a party's standing, without holding that the surcharge violates a constitution A finding only that plaintiffs are likely to succeed, or a temporary restraining order or preliminary injunction that does not itself hold the surcharge unconstitutional Oral rulings from the bench unless reduced to a written order Tentative rulings that are not made final Draft opinions that leak but are not officially issued Settlements or voluntary dismissals Administrative or scheduling orders Orders to show cause Minute orders that do not address the substantive issue in the specified judgment For clarity: If the case is dismissed for lack of jurisdiction, that counts as a ruling only if the judgment refers to jurisdiction Sua sponte rulings count if they match the specified judgment Per curiam opinions and summary orders count as rulings If multiple judges issue separate opinions, the majority/plurality opinion controls