St. Johns County v. Northeast Florida Builders Association

St. Johns County (the county) (defendant) began a study of whether to impose impact fees to finance additional infrastructure to support new growth and development. The county school board requested that the county include educational-facilities impact fees in the study. The county’s consultant submitted a methodology report recommending what actions the county should take to maintain an appropriate level of service for public facilities. The methodology report included a calculation of the cost of educational facilities needed to serve the growing community and suggested a method of allocating that cost to each unit of new residential development. Subsequently, the county enacted the St. Johns County Education Facilities Impact Fee Ordinance (the ordinance). Municipalities in the county had the option to enter into an interlocal agreement with the county to collect fees under the ordinance. The ordinance required that each new building permit required the payment of an impact fee that would be used by the school board to fund educational facilities. The Northeast Florida Builders Association (the builders) (plaintiff) filed suit against the county seeking a declaratory judgment that the ordinance was unconstitutional. The trial court granted summary judgment for the builders and declared that the ordinance was unconstitutional. The county appealed, but the district court affirmed the trial court’s judgment.