The Ninth Circuit upheld a city eviction moratorium against a contracts clause challenge. Apartment Ass'n of Los Angeles County, Inc. v. City of Los Angeles, 2021 WL 3745777 (9th Cir. 2021). While the law did affect contract rights, it was reasonable and appropriate and did not constitute retroactive deprivation of vested rights as required for the clause to apply. The court cited Home Building & Loan Ass'n v. Blaisdell, 290 U.S. 398 (1934), a Supreme Court precedent that was on point and has not been repudiated by the current Court.  The Ninth Circuit also cited the recent 2018 case of Sveen v. Melin, 138 S. Ct. 1815 (2018) which adopted a two-step test, asking whether the law imposes a "substantial" impairment of contract rights, and, if so, whether the law is "appropriate" and  "reasonable" way to advance a legitimate public purpose. 

The court did not reach the question of whether the law imposed a substantial impairment of contract rights because even if it did, the law was a reasonable way to protect the public from the public health effects of displacement from homes during a pandemic.