St. Johns River Water Management District v. Koontz, 77 So. 3d 1220

Koontz sought permits from St. Johns River Water Management District to develop more of his Orange County property; the district denied the permits based on environmental considerations and offered offsite mitigation or other conditions; the circuit court found a taking under Nollan/Dolan and awarded damages; the Fifth District agreed that exactions principles applied but extended Nollan/Dolan beyond land dedications; this Court granted review to determine the scope of exactions takings and whether those tests apply when no real property is dedicated and no permit is issued; the Court ultimately held that Nollan/Dolan apply only to real-property dedications and permit issuance, and this case does not present an exaction because no permit was issued and no property was taken.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nollan/Dolan apply to non-land exactions or permit-denial cases	Koontz urged Nollan/Dolan; argued exaction occurred despite no land dedication	St. Johns argued the exactions doctrine can apply beyond land dedications	Inapplicable beyond real-property dedications and actual permit issuance
Whether a monetary off-site mitigation condition constitutes a taking	Koontz contends the condition is an exaction requiring compensation	St. Johns contends no taking since no real property was taken	Even if applicable, not present here as no permit was issued and no funds expended

Nollan v. California Coastal Comm'n, 483 U.S. 825 (1987) (essential nexus and public-use condition for permit exactions)
Dolan v. City of Tigard, 512 U.S. 374 (1994) (rough proportionality between exaction and impact of development)
City of Monterey v. Del Monte Dunes at Monterey, Ltd., 526 U.S. 687 (1999) (limits Dolan/Nollan to land-use exactions; not applicable to denial cases)
Lingle v. Chevron U.S.A., Inc., 544 U.S. 528 (2005) (rejects the substantively advancing takings test; clarifies context of Nollan/Dolan)