City of Perris, Plaintiff and Respondent v. Richard C. Stamper, Defendants and Appellants

Summary

The court held that constitutional inquiries concerning the essential nexus and rough proportionality of a development dedication are for the court, not the jury, because they are predominantly legal questions that precede any factual determination about whether the dedication would probably have been imposed. It further held that the project effect rule generally displaces the Porterville valuation doctrine when, at the time a dedication requirement was established, it was probable that the property would be included in the condemnation project, and remanded for factual findings on that issue and reconsideration of the constitutional inquiry. Justice Cuéllar concurred in part and dissented in part, agreeing that the constitutional inquiry belongs to the court but rejecting the majority’s additional project-inclusion limitation on the valuation doctrine.