Koontz v. St. Johns River Water Management District
| Koontz v. St. Johns River Water Management District | |
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| Argued January 15, 2013 Decided June 25, 2013 |
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| Full case name | Coy A. Koontz, Jr., Petitioner v. St. Johns River Water Management District. |
| Citations | 568 U.S. ___ (more)
133 S.Ct. 2586
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| Argument | Oral argument |
| Prior history | Florida Circuit Court, Orange County, entered judgment for landowner; affirmed, District Court of Appeal, 5 So.3d 8 (2009); reversed, Florida Supreme Court, 77 So.3d 1220 (2012); certiorari granted, ___ U.S. ___, 133 S.Ct. 420 (2012 WL 1966013). |
| 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 | |
Koontz v. St. Johns River Water Management District, 568 U.S. ___ (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. It was the first case in which monetary exactions were found to be unconstitutional conditions.
Petitioner Coy Koontz applied to the St. Johns River Water Management District for a permit to develop 3.7 acres of wetlands under the District's jurisdiction. Koontz offered to mitigate the loss of wetlands by conveying to the District a conservation easement over 11 acres of adjacent land. The District declined Koontz's mitigation offer, instead proposing that Koontz either reduce the size of his development to one acre, or pay for improvements to unrelated property owned by the District several miles away. Koontz responded by filing suit against the District in state court.
Following an initial dismissal, appeal, and remand, the Florida Circuit Court ruled that the District's demand for offsite mitigation violated Nollan v. California Coastal Commission and Dolan v. City of Tigard, since the improvements to the District's property lacked either an essential nexus or rough proportionality to the environmental impact of Koontz's proposed development. The state appellate court affirmed, but the Supreme Court of Florida reversed, holding that Nollan and Dolan did not apply because (1) Koontz's permit was denied, rather than granted subject to the unconstitutional condition, and (2) the District sought money rather than a conveyance of real property as a condition to issuing the permit. The Supreme Court granted certiorari to determine the applicability of Nollan and Dolan under these circumstances.
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