Sheetz v. El Dorado County

601 U.S. 267
CourtSupreme Court of the United States
DecidedApril 12, 2024
Docket22-1074
StatusPublished
Cited by20 cases

This text of 601 U.S. 267 (Sheetz v. El Dorado County) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheetz v. El Dorado County, 601 U.S. 267 (2024).

Opinion

PRELIMINARY PRINT

Volume 601 U. S. Part 2 Pages 267–284

OFFICIAL REPORTS OF

THE SUPREME COURT April 12, 2024

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2023 267

Syllabus

SHEETZ v. COUNTY OF EL DORADO, CALIFORNIA

certiorari to the court of appeal of california, third appellate district No. 22–1074. Argued January 9, 2024—Decided April 12, 2024 As a condition of receiving a residential building permit, petitioner George Sheetz was required by the County of El Dorado to pay a $23,420 traffc impact fee. The fee was part of a “General Plan” enacted by the Coun- ty's Board of Supervisors to address increasing demand for public serv- ices spurred by new development. The fee amount was not based on the costs of traffc impacts specifcally attributable to Sheetz's particular project, but rather was assessed according to a rate schedule that took into account the type of development and its location within the County. Sheetz paid the fee under protest and obtained the permit. He later sought relief in state court, claiming that conditioning the building per- mit on the payment of a traffc impact fee constituted an unlawful “exac- tion” of money in violation of the Takings Clause. In Sheetz's view, the Court's decisions in Nollan v. California Coastal Comm'n, 483 U. S. 825, and Dolan v. City of Tigard, 512 U. S. 374, required the County to make an individualized determination that the fee imposed on him was necessary to offset traffc congestion attributable to his project. The courts below ruled against Sheetz based on their view that Nollan and Dolan apply only to permit conditions imposed on an ad hoc basis by administrators, not to a fee like this one imposed on a class of property owners by Board-enacted legislation. 84 Cal. App. 5th 394, 402, 300 Cal. Rptr. 3d 308, 312. Held: The Takings Clause does not distinguish between legislative and administrative land-use permit conditions. Pp. 273–280. (a) When the government wants to take private property for a public purpose, the Fifth Amendment's Takings Clause requires the govern- ment to provide the owner “just compensation.” The Takings Clause saves individual property owners from bearing “public burdens which, in all fairness and justice, should be borne by the public as a whole.” Armstrong v. United States, 364 U. S. 40, 49. Even so, the States have substantial authority to regulate land use, see Village of Euclid v. Am- bler Realty Co., 272 U. S. 365, and a state law that merely restricts land use in a way “reasonably necessary to the effectuation of a substantial government purpose” is not a taking unless it saps too much of the property's value or frustrates the owner's investment-backed expecta- tions. Penn Central Transp. Co. v. New York City, 438 U. S. 104, 123, 268 SHEETZ v. COUNTY OF EL DORADO

127. Similarly, when the government can deny a building permit to further a “legitimate police-power purpose,” it can also place conditions on the permit that serve the same end. Nollan, 483 U. S., at 836. For example, if a proposed development will “substantially increase traffc congestion,” the government may condition the building permit on the owner's willingness “to deed over the land needed to widen a public road.” Koontz v. St. Johns River Water Management Dist., 570 U. S. 595, 605. But when the government withholds or conditions a building permit for reasons unrelated to its legitimate land-use interests, those actions amount to extortion. See Nollan, 483 U. S., at 837. The Court's decisions in Nollan and Dolan address the potential abuse of the permitting process by setting out a two-part test modeled on the unconstitutional conditions doctrine. See Perry v. Sindermann, 408 U. S. 593, 597. First, permit conditions must have an “essential nexus” to the government's land-use interest, ensuring that the govern- ment is acting to further its stated purpose, not leveraging its permit- ting monopoly to exact private property without paying for it. See Nollan, 483 U. S., at 837, 841. Second, permit conditions must have “rough proportionality” to the development's impact on the land-use in- terest and may not require a landowner to give up (or pay) more than is necessary to mitigate harms resulting from new development. See Dolan, 512 U. S., at 391, 393; Koontz, 570 U. S., at 612–615. Pp. 273–276. (b) The County's traffc impact fee was upheld below based on the view that the Nollan/Dolan test does not apply to monetary fees im- posed by a legislature, but nothing in constitutional text, history, or precedent supports exempting legislatures from ordinary takings rules. The Constitution provides “no textual justifcation for saying that the existence or the scope of a State's power to expropriate private property without just compensation varies according to the branch of government effecting the expropriation.” Stop the Beach Renourishment, Inc. v. Florida Dept. of Environmental Protection, 560 U. S. 702, 714 (plurality opinion). Historical practice similarly shows that legislation was the conventional way that governments at the state and national levels ex- ercised their eminent domain power to obtain land for various govern- mental purposes, and to provide compensation to dispossessed landown- ers. The Fifth Amendment enshrined this longstanding practice. Precedent points the same way as text and history. A legislative ex- ception to the Nollan/Dolan test “conficts with the rest of [the Court's] takings jurisprudence,” which does not otherwise distinguish between legislation and other offcial acts. Knick v. Township of Scott, 588 U. S. 180, 185. That is true of precedents involving physical takings, regula- tory takings, and the unconstitutional conditions doctrine which under- lies the Nollan/Dolan test. Pp. 276–279. Cite as: 601 U. S. 267 (2024) 269

(c) As the parties now agree, conditions on building permits are not exempt from scrutiny under Nollan and Dolan just because a legislative body imposed them. Whether a permit condition imposed on a class of properties must be tailored with the same degree of specifcity as a permit condition that targets a particular development is an issue for the state courts to consider in the frst instance, as are issues concerning whether the parties' other arguments are preserved and how those ar- guments bear on Sheetz's legal challenge. Pp. 279–280. 84 Cal. App. 5th 394, 300 Cal. Rptr. 3d 308, vacated and remanded.

Barrett, J., delivered the opinion for a unanimous Court. Sotomayor, J., fled a concurring opinion, in which Jackson, J., joined, post, p. 280. Gorsuch, J., fled a concurring opinion, post, p. 281. Kava- naugh, J., fled a concurring opinion, in which Kagan and Jackson, JJ., joined, post, p. 284.

Paul J. Beard II argued the cause for petitioner. With him on the briefs were Brian T. Hodges, Lawrence G. Salz- man, and Damien M. Schiff. Aileen M. McGrath argued the cause for respondent. With her on the brief were Zach ZhenHe Tan, Michael Weis- buch, Pratik A. Shah, Z. W.

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Bluebook (online)
601 U.S. 267, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheetz-v-el-dorado-county-scotus-2024.