Scarbrough Group v. Worley, 290 Ga. 234

Appellants own three parcels totaling 788 acres annexed by Peachtree City in May 2007 via the 100% method.
Worley, a Peachtree City resident, challenged the 2007 annexation and the City’s 2008 re-zoning in a 2007 declaratory action and later sought injunctive relief.
In 2008 the City annexed a 35-acre unincorporated island created by the 2007 annexation, attempting to cure the defect.
Trial court dismissed most of Worley’s complaint in 2009 for lack of standing; later deemed moot after the island’s 2008 annexation.
Court of Appeals reversed, holding Worley could obtain injunctive relief despite mootness, based on a void ab initio 2007 annexation.
Georgia Supreme Court held the appeal was moot when docketed and must be dismissed, thus vacating the Court of Appeals judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal was moot	Worley contends the 2007 annexation was ultra vires and void ab initio, so mootness does not apply.	City and appellants argue subsequent curing annexation rendered the issue moot.	Appeal dismissed as moot; cured annexation vacates mootness.
Whether Worley had standing to seek injunctive relief	Worley, as a citizen-taxpayer, had standing to challenge illegality of the annexation.	Appellants dispute standing requirements under the statute and absence of live controversies.	No need to decide standing; mootness disposition controls.

Chastain v. Baker, 255 Ga. 432 (1986) (mandatory dismissal of moot appeals)
Collins v. Lombard Corp., 270 Ga. 120 (1998) (mootness when questions present abstract and existing facts)
Gober v. Colonial Pipeline Co., 228 Ga. 668 (1972) (avoidance of mootness when there is a direct benefit to be conferred)
Emmons v. City of Arcade, 270 Ga. 196 (1998) (injunctive relief where statutory notice issues render appeal moot)
Richmond County Business Assn. v. Richmond County, 223 Ga. 337 (1967) (vitiates invalid election or procedural defects; mootness considerations)