Koontz v. St. Johns River Water Management Dist.

Summary

The Supreme Court held that the Nollan-Dolan standard applies to permit conditions even if the government denies the permit when the applicant refuses to comply, and even when the demand is for money rather than an interest in real property. The Court reasoned that the unconstitutional conditions doctrine protects property rights from extortionate demands regardless of whether a permit is ultimately approved, and monetary exactions linked to specific property interests implicate the Takings Clause. Justice Kagan dissented, arguing that monetary obligations do not constitute takings under Eastern Enterprises and that no demand was made here.