Sheetz v. County of El Dorado

Sheetz v. County of El Dorado
Argued January 9, 2024
Decided April 12, 2024
Full case nameGeorge Sheetz v. County of El Dorado, California
Docket no.22-1074
ArgumentOral argument
Case history
Prior84 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
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Amy Coney Barrett · Ketanji Brown Jackson
Case opinions
MajorityBarrett, joined by unanimous
ConcurrenceSotomayor, joined by Jackson
ConcurrenceGorsuch
ConcurrenceKavanaugh, 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.