Koontz v. St. Johns River Water Management District
United States Supreme Court
570 U.S. 595 (2013)
Coy Koontz (plaintiff) applied to the St. Johns River Water Management District (defendant) for a permit to develop wetlands he owned, but the District denied the permit because Koontz wouldn't agree either to shrink his development and deed a conservation easement over the rest of his land, or to pay for improvements to District-owned land several miles away. Koontz sued, claiming the denial violated the Takings Clause under the framework of Nollan v. California Coastal Commission and Dolan v. City of Tigard. The trial court agreed with Koontz, but the Florida Supreme Court reversed, reasoning that Nollan and Dolan didn't apply because the District had denied the permit outright rather than conditioning approval on a demand, and because it had sought money rather than a direct interest in real property. The U.S. Supreme Court granted certiorari.
Whether the government's demand for property from a land-use permit applicant must satisfy a nexus and rough-proportionality test between the demand and the effects of the proposed land use, even when the government denies the permit rather than conditioning it, and even when the demand is for money rather than an interest in real property.