The South Carolina Court of Appeals ruled, in August, that a developer frustrated in its attempts to have a development plan approved in light of a County Council’s efforts to pass a height limitation ordinance, where there had been no limitation before, could maintain an action against Council members, in their unofficial, individual capacities for civil conspiracy, where the developer was able to allege the required elements of civil conspiracy in its complaint. On the other hand, where that complaint names the Council members only as individuals, and not as officials, no causes of action addressing their actions as Council members could be maintained.