In Byrd v. Irmo High School, 321 S.C. 426, 468 S.E.2d 861 (1996), a student challenged the school district's order which suspended him for ten days for coming onto campus after consuming alcohol. The court chose to hear the case because school suspensions are very brief and are usually completed before judicial review can take place. Id. at 432, 468 S.E.2d at 864. The South Carolina Supreme Court clarified the capable of repetition but evading review principle, noting an inconsistency in our courts' decisions on the subject. "Some cases have held that under the exception, a court can take jurisdiction only if (1) the challenged action in its duration was too short to be fully litigated prior to its cessation or expiration; and (2) there is a reasonable expectation that the same complaining party will be subjected to the action again. Other cases have taken a less restrictive approach in defining the exception, holding that a court can take jurisdiction, despite mootness, if the issue raised is capable of repetition but evading review. In effect, this latter approach differs from the former in that it does not require a reasonable expectation that the same complaining party be subjected to the action again." (Id. at 431, 468 S.E.2d at 864.) The court clarified the inconsistency with the pronouncement: "this less restrictive approach is the appropriate standard in determining the applicability of the evading review exception of the mootness doctrine." Id. at 432, 468 S.E.2d at 864.