Croft v. Town of Summerville

Summary

The South Carolina Supreme Court held that an appeal challenging a municipal architectural review board's approval of a development project was moot after the developer abandoned the project. The court declined to apply the capable-of-repetition and public-interest exceptions to mootness, vacated the Court of Appeals' decision, and dismissed the appeal.

Holdings

1. The appeal was moot because the developer abandoned the project, and a judgment for either party would provide no practical legal relief.
2. The capable-of-repetition-yet-evading-review exception did not apply because the appeal became moot through the developer's abandonment of the project, not because the challenged issues were inherently too short-lived for appellate review.
3. The public-interest exception did not apply because, although public access to governmental activity is important, the case presented no imperative or manifest urgency requiring a ruling on the alleged Freedom of Information Act and ordinance violations.

Questions Presented

1. Whether the developer's abandonment of the proposed development rendered Petitioners' challenge to the Board's approval moot.
2. Whether the capable-of-repetition-yet-evading-review exception permitted the court to decide the merits despite mootness.
3. Whether the public-interest exception to mootness permitted the court to decide alleged Freedom of Information Act and municipal-ordinance violations.

Disposition

vacated