The U.S. Supreme Court has just granted certiorari in an exaction/taking case, a la Nollan and Dolan.
The questions presented are:
1. Whether the government can be held liable for a taking when it refuses to issue a land-use permit on the sole basis that the permit applicant did not accede to a permit condition that, if applied, would violate the essential nexus and rough proportionality tests set out in Nollan v. California Coastal Commission , 483 U.S. 825 (1987), and Dolan v. City of Tigard, 512 U.S. 374 (1994); and
2. Whether the nexus and proportionality tests set out in Nollan and Dolan apply to a land-use exaction that takes the form of a government demand that a permit applicant dedicate money, services, labor, or any other type of personal property to a public use.
The case is Koontz v. St. John’s River Water Mgmnt. Dist., No. 11-1447. The opinion below (by the Florida Supreme Court) may be found at 77 So.3d 1220 (Fla. 2011)