Law School Case Brief
Koontz v. St. Johns River Water Mgmt. Dist. - 570 U.S. 595, 133 S. Ct. 2586 (2013)
The principles that undergird the decisions in Nollan and Dolan do not change depending on whether the government approves a land use permit on the condition that the applicant turn over property or denies a permit because the applicant refuses to do so. The United States Supreme Court has often concluded that denials of governmental benefits were impermissible under the unconstitutional conditions doctrine. The government may not deny a benefit to a person on a basis that infringes his constitutionally protected interests. Regardless of whether the government ultimately succeeds in pressuring someone into forfeiting a constitutional right, the unconstitutional conditions doctrine forbids burdening the United States Constitution’s enumerated rights by coercively withholding benefits from those who exercise them.
Coy Koontz, Sr., whose estate is represented here by petitioner, sought permits to develop a section of his property from respondent St. Johns River Water Management District (District). Consistent with Florida law, the District required permit applicants wishing to build on wetlands to offset the resulting environmental damage. Koontz offered to mitigate the environmental effects of his development proposal by deeding to the District a conservation easement on nearly three-quarters of his property. The District rejected Koontz's proposal and informed him that it would approve construction only if he reduced the size of his development and deeded to the District a conservation easement on the resulting larger remainder of his property or hired contractors to make improvements to District-owned wetlands several miles away. Believing the District's demands to be excessive in light of the environmental effects his proposal would have caused, Koontz filed suit under a state law that provides money damages for agency action that is an “unreasonable exercise of the state's police power constituting a taking without just compensation.”
The trial court found the District's actions unlawful because case law held that the government may not condition the approval of a land-use permit on the owner's relinquishment of a portion of his property unless there is a nexus and rough proportionality between the government's demand and the effects of the proposed land use. The state appellate court affirmed, but the Florida Supreme Court reversed on two grounds. First, it held that petitioner's claim failed because the District denied the application. Second, the State Supreme Court held that a demand for money cannot give rise to a claim. The U.S. Supreme Court granted certiorari review.
Was a money claim for damages proper?
The U.S. Supreme Court held that, under the Fifth Amendment, the District's demand for property from the landowner had to satisfy the requirements of a nexus and rough proportionality to the development's proposed impacts, even though the District denied the permit. Whether the posture of the case presented some federal obstacle to adjudicating the landowner's unconstitutional conditions claim was a matter for the state courts to consider on remand. The fact that monetary exactions were involved did not preclude applicability of precedent under Nollan and Dolan because the demand for offsite mitigation was tied to a particular parcel of land, a per se Fifth Amendment takings approach was the proper mode of analysis.
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