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In page Mootness:
"The Court cited Southern Pacific Terminal Co. v. ICC, 219 U.S. 498 (1911), which had held that a case was not moot when it presented an issue that was "capable of repetition, yet evading review". Perhaps in response to increasing workloads at all levels of the judiciary, the recent trend in the Supreme Court and other U.S. courts has been to construe this exception rather narrowly.[citation needed]
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