South Carolina Retirement System Investment Commission v. Loftis

Summary

The South Carolina Supreme Court dismissed as moot a petition for a writ of mandamus seeking to compel the custodian of the South Carolina Retirement Systems Group Trust to authorize funding of a specific private-equity investment. The court held that the custodian’s authorization of the transfer left no act for the court to order and declined to consider broader relief concerning future investments.

Holdings

1. The petition for a writ of mandamus was moot because Loftis performed the precise act the Commission sought to compel—authorizing funding of the Warburg Pincus Fund XI investment—and no effective relief remained for the court to order.
2. The court declined to issue prospective injunctive relief directing Loftis to comply with Commission directives concerning future investments because the petition sought only an order concerning the completed Warburg Pincus Fund XI transfer and presented no remaining justiciable controversy.

Questions Presented

1. Whether the Commission's petition for a writ of mandamus became moot after Loftis authorized the specific transfer of funds sought in the petition.
2. Whether the court should issue prospective injunctive relief directing the custodian to follow Commission directives concerning future investments despite completion of the particular act requested.

Disposition

dismissed