Koontz v. St. Johns River Water Management District
2013 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Koontz v. St. Johns River Water Management District, 570 U.S. 595 (2013), is a United States Supreme Court case in which the Court held that land-use agencies imposing conditions on the issuance of development permits must comply with the "nexus" and "rough proportionality" standards of Nollan v. California Coastal Commission and Dolan v. City of Tigard, even if the condition consists of a requirement to pay money, and even if the permit is denied for failure to agree to the condition.[1] It was the first case in which monetary exactions were found to be unconstitutional conditions.
Quick Facts Koontz v. St. Johns River Water Management District, Argued January 15, 2013 Decided June 25, 2013 ...
Koontz v. St. Johns River Water Management District | |
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Argued January 15, 2013 Decided June 25, 2013 | |
Full case name | Coy A. Koontz, Jr., Petitioner v. St. Johns River Water Management District. |
Citations | 570 U.S. 595 (more) 133 S. Ct. 2586; 186 L. Ed. 2d 697; 2013 U.S. LEXIS 4918; 76 ERC 1649; 81 U.S.L.W. 4606 |
Argument | Oral argument |
Case history | |
Prior | Florida Circuit Court, Orange County, entered judgment for landowner; affirmed, District Court of Appeal, 5 So. 3d 8 (Fla. Dist. Ct. App. 2009); reversed, 77 So. 3d 1220 (Fla. 2012); cert. granted, 568 U.S. 936 (2012). |
Holding | |
When a discretionary land-use permit is denied because the applicant declines to pay for improvements to other, unrelated property, a challenge to the constitutionality of the denial must be evaluated under the "essential nexus" standard of Nollan v. California Coastal Commission and the "rough proportionality" requirement of Dolan v. City of Tigard. | |
Court membership | |
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Case opinions | |
Majority | Alito, joined by Roberts, Scalia, Kennedy, Thomas |
Dissent | Kagan, joined by Ginsburg, Breyer, Sotomayor |
Laws applied | |
U.S. Const. amend. V |
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