Andrew Cuomo said his office had received 25,000 complaints of reopening violations by businesses as New Yorkers flocked to streets to enjoy a weekend of late spring sunshine.

"Lots of violations of social distancing, parties in the street, restaurants and bars ignoring laws," he tweeted.

"Enforce the law or there will be state action," Cuomo warned local authorities.

New York City, the epicenter of America's coronavirus outbreak, is in phase one of Cuomo's four-phase reopening plan.

Restaurants and bars are allowed to offer takeaway food and drinks but are not permitted to offer outside seating until phase two, expected later this month.

Under social distancing guidelines, gatherings are meant to be capped at ten people.

It is also illegal to drink alcohol in public places in New York. 

The governor retweeted a video showing hundreds of people partying in a street in Manhattan's East Village on Friday evening with the words, "Don't make me come down there."

COVID-19 has killed almost 31,000 people in New York state, according to Johns Hopkins University.

At the height of the crisis in early April almost 800 people were dying a day in the state. 

On Sunday, Cuomo reported that 23 state residents had succumbed to COVID-19 in the past 24 hours -- a new record low.

He also said that total virus hospitalizations fell to 1,657, the lowest since March 20.