Spiking COVID-19 cases in Texas have forced Simon Property to close the Cielo Vista Mall in El Paso, Texas, according to CNBC.

As Coronavirus cases rise around the country, many other mall operators could be following Simon’s lead, which could mean a second round of COVID shutdowns after the initial wave last Spring.

Right now, Cielo Vista Mall is Simon’s only property that is closed. CEO David Simon told CNBC that he thought enclosed malls were being treated “unfairly and inconsistently,” and there wasn’t sufficient proof that the mall environment “spreads anything.”

However, a recent study published in the journal Nature, found that restaurants, gyms and indoor venues accounted for 8 in 10 new infections from March to May in 10 cities, according to The New York Times. The study showed that less affluent areas were harder hit by COVID because the public venues in those areas were more crowded than in affluent areas. It also indicated that setting caps on the number of people in a facility could help slow the disease’s spread. 

Before shutting down Cielo Vista Mall in El Paso, all of Simon’s malls had been open since Oct. 7. During Q3, seven of its retail properties in California were temporarily closed on July 15 due to a governmental order. Six of the properties reopened on Aug. 31. 

As of Sept. 30, 2020, Simon’s occupancy was 91.4%, and its base minimum rent per square foot was $56.13, which was an increase of 2.9% year-over-year.

While Simon and enclosed mall owners have struggled with shutdowns, open-air retail has generally remained open throughout the pandemic.

“In open-air centers in many jurisdictions, retailers are currently generally permitted to operate with in-store shopping, although subject to some conditions aimed at limiting congestion and high customer traffic within the store,” Scott Grossfeld, a partner at Cox, Castle & Nicholson, told GlobeSt.com in an earlier interview

Landlords and retailers in enclosed retail spaces have tried to compensate by offering curbside and other pick-up services, according to Grossfeld. “Although such options provide retailers with some element of economic relief, they, unfortunately, are not the same [or as good] as providing in-store shopping,” he told GlobeSt.com