Sheetz v. County of El Dorado | |
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Argued January 9, 2024 Decided April 12, 2024 | |
Full case name | George Sheetz v. County of El Dorado, California |
Docket no. | 22-1074 |
Argument | Oral argument |
Case history | |
Prior | 84 Cal.App.5th 394 (Cal. Ct. App. 2022) |
Questions presented | |
Is a monetary exaction imposed by a local government as a condition for a building permit exempt from the “essential nexus” and “rough proportionality” requirements established in Nollan v. Cal. Coastal Comm'n and Dolan v. City of Tigard, simply because the exaction is authorized by local legislation? | |
Holding | |
The Takings Clause does not distinguish between legislative and administrative land-use permit conditions. | |
Court membership | |
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Case opinions | |
Majority | Barrett, joined by unanimous |
Concurrence | Sotomayor, joined by Jackson |
Concurrence | Gorsuch |
Concurrence | Kavanaugh, joined by Kagan, Jackson |
Laws applied | |
U.S. Const. amend. V |
Sheetz v. County of El Dorado (Docket No. 22-1074) is a United States Supreme Court case regarding permit exactions under the Takings Clause. The Supreme Court held, in a unanimous opinion by Justice Amy Coney Barrett, that fees for land-use permits must be closely related and roughly proportional to the effects of the land use – the test established by Nollan v. California Coastal Commission and Dolan v. City of Tigard – even if the fees were established by legislation rather than through an individualized assessment.