 In the case of the Maryland statute, the state statute was impermissibly regulating transactions between manufacturers and distributors that took place wholly outside of Maryland.Lefkowitz has been deeply involved in the "pro bono" representation of New York parents who assert that the teacher-tenure system in place has led to inadequate education for countless students across the State because it often precludes dismissal of ineffective teachers.In 2018, a New York appellate court ruled that the case could go on, rejecting the State's argument that some changes the New York legislature had enacted necessarily served to solve the problems.