You think Cuomo is going to not allow fans in the stands until there is 0 cases of COVID? Phase 4 specifically mentions entertainment opening. That means people in seats. Phase 4 doesn't happen when there is 0 COVID cases. Hell, some places are going to be in Phase 4 as soon as two-three weeks from now, and there are venues in those locations. They will be able to open. Now, they'd have to book someone and people would have to be willing to buy tickets to an event, but I don't think there will be a shortage of that, especially during the summer.
This is something as small as a movie theater. If they open, do you think that the owner of the theater is going to let people come in and potentially spread COVID and not have something that doesn't make them liable to be sued? They didn't bring COVID into their theater. They'd be closed from the contact tracing if multiple people got it and they trace it back to the theater. They'll be told what they need to do to address the issue, probably get inspected to make sure they are up to COVID standards, but owners are going to make it so they cannot be sued because someone walked into their building and they got COVID and it could be traced back to that place in time.
They could be fined by the state, but being sued by an individual that was there and go sick? If anyone is planning on entering a place that has a bunch of people, be prepared to be signing a lot of documentation to remove their liability of you getting COVID. You don't want to sign it, you don't have to go in. It comes down to your own personal choice after a while.