Matter of Hearst Corp. v. Clyne

In Matter of Hearst Corp. v. Clyne, 50 NY2d 707 [1980] the Court of Appeals identified three factors which would justify an exception to the mootness doctrine: (1) a likelihood of repetition, either between the parties or among other members of the public; (2) a phenomenon typically evading review; (3) a showing of significant or important questions not previously passed on, i.e., substantial and novel issues. (50 NY2d at 714-715.)