What is the test for establishing a curfew in a local emergency?

2 "During a local emergency the governing body of a political subdivision, or officials designated thereby, may promulgate orders and regulations necessary to provide for the protection of life and property, including orders or regulations imposing a curfew within designated boundaries where necessary to preserve the public order and safety. Such orders and regulations and amendments and recissions thereof shall be in writing and shall be given widespread publicity and notice." (Compare Gayle v. Governor of Guam (D.Guam 1976) 414 F.Supp. 636, 638, where a curfew was invalidated because local law did not authorize the imposition of a curfew in the aftermath of a natural disaster.)