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Koontz v. St. Johns River Water Management District
United States Supreme Court
570 U.S. 595, 133 S.Ct. 2586, 186 L.Ed.2d 697 (2013)
Coy Koontz (plaintiff) applied to the St. Johns River Water Management District (District) (defendant) for a permit to develop a portion of his property that was zoned as wetlands. The District denied the application because Koontz refused to either (1) reduce the size of his development area and deed an easement to the government on the rest of the property, or (2) fund improvements to District-owned land several miles away. Koontz brought suit against the District, arguing that its decision violated the Takings Clause of the Fifth Amendment. The trial court found in favor of Koontz, holding that the District’s denial of the application violated Nollan v. California Coastal Commission, 483 U.S. 825 (1987), and Dolan v. City of Tigard, 512 U.S. 374 (1994). The Florida Supreme Court reversed, distinguishing Nollan and Dolan on the grounds that (1) the District did not condition approval of the application on any action by Koontz, but rather denied it, and (2) the District requested monetary payment rather than a direct interest in real property. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Alito, J.)
Dissent (Kagan, J.)
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