Koontz v. St. Johns River Water Management Dist.
133 S. Ct. 2586
| SCOTUS | 2013Background
- Coy Koontz sought state permits to develop 3.7 acres of a 14.9‑acre Florida parcel that was partly wetlands; he offered to deed a conservation easement on ~11 acres as mitigation.
- The St. Johns River Water Management District rejected that mitigation as insufficient and conditioned approval either on (a) a much smaller footprint plus a larger easement, or (b) offsite improvements to District wetlands several miles away (paid/contracted by Koontz).
- Koontz refused, the District denied the permits, and Koontz sued under a Florida statute authorizing damages when an agency’s action is an unreasonable exercise of police power constituting a taking without just compensation.
- The trial court and Florida District Court of Appeal held the District’s demands violated Nollan/Dolan (nexus and rough proportionality); the Florida Supreme Court reversed, distinguishing (1) denials from conditional approvals and (2) money exactions from conveyance of real property.
- The U.S. Supreme Court granted certiorari to decide (i) whether Nollan/Dolan apply when a permit is denied rather than approved with a condition, and (ii) whether monetary exactions are subject to Nollan/Dolan.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Nollan/Dolan apply when a permit is denied (condition precedent) rather than approved with a condition (condition subsequent)? | Nollan/Dolan protect against coercive exactions regardless of approval/denial framing. | Distinction is dispositive; Nollan/Dolan apply only when permit is granted subject to a condition. | Nollan/Dolan apply regardless of whether the permit was denied or approved; framing cannot evade the doctrine. |
| Do Nollan/Dolan apply when the exaction is a monetary payment/monetary mitigation ("monetary exaction")? | Monetary exactions tied to a particular parcel are equivalent to property exactions and must meet nexus and rough proportionality. | Eastern Enterprises bars treating ordinary monetary obligations as takings; money demands should be treated differently from property takings. | Monetary exactions that are directly linked to a specific parcel fall within Nollan/Dolan scrutiny. |
| Does providing an alternative (less ambitious permit that would satisfy nexus/proportionality) defeat the claim? | Koontz: the denial concerned the actual project he sought (2.7 acres), so an alternative does not cure an unconstitutional condition on the proposed project. | District: because it offered a lawful alternative, there was no unconstitutional condition affecting Koontz. | Offering an alternative that itself satisfies Nollan/Dolan would avoid liability, but here the offered alternative did not moot review of the challenged demand. |
| Procedural posture and remedies: wrong forum, wrong remedy, timing; can Koontz obtain money damages? | Koontz relied on the Florida damages statute; the federal rule on doctrine applicability is reviewable, and state remedies questions are for state courts. | District argued Koontz sued in wrong forum and is not entitled to federal takings damages for a denied permit. | U.S. Supreme Court limited decision to federal constitutional rule; remanded state-law remedies and procedural questions to Florida courts to decide in the first instance. |
Key Cases Cited
- Nollan v. California Coastal Comm'n, 483 U.S. 825 (1987) (establishes nexus requirement for land‑use exactions)
- Dolan v. City of Tigard, 512 U.S. 374 (1994) (establishes rough proportionality requirement for exactions)
- Lingle v. Chevron U.S.A. Inc., 544 U.S. 528 (2005) (frames Nollan/Dolan as an application of the unconstitutional conditions doctrine)
- Eastern Enter. v. Apfel, 524 U.S. 498 (1998) (holds ordinary monetary obligations generally do not constitute takings absent a specific property interest)
- Penn Central Transp. Co. v. New York City, 438 U.S. 104 (1978) (multi‑factor regulatory takings test for diminution‑in‑value claims)
- United States v. American Library Assn., Inc., 539 U.S. 194 (2003) (unconstitutional conditions doctrine applies even when benefit is discretionary)
- Brown v. Legal Foundation of Wash., 538 U.S. 216 (2003) (confiscation of client funds held in escrow can constitute a taking despite similarity to taxation)