Permit demands and property rights
Koontz v. St. Johns River Water Management District
In brief
The Court ruled that permit-condition tests cover property demands even when a permit is denied and also apply to demands for money, then sent Koontz’s case back.
- Where it stands
- Decided
Decided 5-4 · June 25, 2013 · Opinion by Justice Alito
- What it’s about
- Koontz challenged the St. Johns River Water Management District’s demand for property or money to approve his land-use permit.
- Who it affects
- For land-use permit applicants, property demands must be tied to the project and roughly match its effects, even if the permit is denied; the same rules apply to demands for money.
Summary: written with AI from the case record.
What it's about
The Court ruled these demands must be connected to the project and roughly matched to its effects even when the permit is denied; it overturned the Florida Supreme Court’s ruling (reversed it) and sent the case back (remanded it).
The case concerned what public agencies may require in return for approving land-use permits.
Question presented
Is the government liable for a taking when it refuses to issue a permit until the landowner has agreed to dedicate personal resources to a public use?
What the Court decided
Holding
1. The government’s demand for property from a land-use permit applicant must satisfy the Nollan / Dolan requirements even when it denies the permit. 2. The government’s demand for property from a land-use permit applicant must satisfy the Nollan / Dolan requirements even when its demand is for money. 77 So. 3d 1220, reversed and remanded.
- Result
- Reversed
The vote
From the opinions
“I think the Court gets the first question it addresses right.”
What's next
The case returns to the Florida Supreme Court for further proceedings. The ruling did not itself award Koontz compensation.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Koontz
Opinion added: Koontz
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.