Koontz v. St. John’s River Water Management District & Housing


Housing Affordability Institute released a white paper examining the United States Supreme Court ruling in Koontz v. St. John’s River Water Management. This paper is the latest in the Insittute’s Federal Legal Precedent series outlining influential, precedent-setting court decisions at the federal level and illustrates the impact on housing and development.

Under Koontz, the standards of “essential nexus” and “rough proportionality” were held applicable to monetary exactions imposed on land use development.

Koontz expanded on similar takings cases, notably Nollan v. California Coastal Commission and Dolan v. City of Tigard. The United States Supreme Court ruled that the Nollan-Dolan test applies even when the approving entity demand money and/or when the project is denied. Since Koontz, the government cannot impose a monetary exaction and circumvent the Nollan-Dolan test.