Sheetz v. El Dorado County

George Sheetz applied to place a manufactured home on his property in El Dorado County, California. The county conditioned permit approval on payment of a traffic impact mitigation fee of over $23,000, calculated under a legislatively adopted rate schedule. Sheetz paid under protest and sued, arguing the fee was an unconstitutional taking because the county did not make an individualized determination of the traffic impacts attributable to his specific project. The California courts rejected his claim, holding that legislatively imposed permit conditions are not subject to the heightened scrutiny required by Nollan and Dolan. The U.S. Supreme Court unanimously reversed, ruling that legislatively prescribed permit conditions are not exempt from the Takings Clause scrutiny.

The Supreme Court unanimously held that legislatively imposed permit conditions are not exempt from the unconstitutional conditions doctrine. The ruling vacated the California judgment and remanded the case for further proceedings to determine whether the traffic impact fee satisfied the Nollan/Dolan nexus and proportionality tests.

The central dispute was whether the Takings Clause requirement for an essential nexus and rough proportionality, as established in Nollan v. California Coastal Commission and Dolan v. City of Tigard, applies to development impact fees imposed through general legislation, rather than individualized administrative adjudications.

This decision significantly restricts local government authority to impose standardized impact fees on development without demonstrating a direct proportional link to a specific project's impacts. It extends constitutional property protections to legislative exactions, potentially opening numerous existing municipal fee schedules to legal challenges and reshaping public finance mechanisms for infrastructure across the nation.