Koontz v. St. Johns River Water Mgmt. Dist., 133 S. Ct. 2586 (2013).
Impact fees must be roughly proportional to the impact of the project and have a nexus to the impact of the project.
Applicant in Florida sought to develop a portion of his property located in a state-designated wetlands area. Applicant proposed to deed a conservation easement to the local water management district, but the proposal was rejected and Applicant was told to either reduce the size of his development and increase the easement area, or provide a significant fee in lieu of cash to provide off-site wetland mitigation. Applicant sued and the Florida Supreme Court ruled the conditions were not excessive under Nollan v. California Coastal Commission, 483 U.S. 825 (1987), and Dolan v City of Tigard, 512 U.S. 374 (1994). The U.S. Supreme Court reversed. The Court held that the Nollan-Dolan standard requires that monetary demands be roughly proportional to the impact of the project and have a nexus to the impact of the project.
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