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Sheetz v. County of El Dorado, California

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Supreme Court of the United States
Sheetz v. County of El Dorado, California
Term: 2023
Important Dates
Argued: January 9, 2024
Decided: April 12, 2024
Outcome
Vacated and remanded
Vote
9-0
Majority
Amy Coney Barrett • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Ketanji Brown Jackson
Concurring
Sonia Sotomayor • Ketanji Brown Jackson; Neil Gorsuch; Brett Kavanaugh • Elena Kagan • Ketanji Brown Jackson

Sheetz v. County of El Dorado, California is a case that was decided by the Supreme Court of the United States on April 12, 2024, during the court's October 2023-2024 term. The case was argued before the Court on January 9, 2024.

In a unanimous ruling, the Court vacated the California Third District Court of Appeals' judgment and remanded the case for further proceedings, holding that "the Takings Clause does not distinguish between legislative and administrative land-use permit conditions."[1] Justice Amy Coney Barrett delivered the majority opinion of the Court. Justice Sonia Sotomayor filed a concurring opinion, joined by Justice Ketanji Brown Jackson. Justice Neil Gorsuch filed a concurring opinion. Justice Brett Kavanaugh filed a concurring opinion, joined by Justices Elena Kagan and Ketanji Brown Jackson. Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the unconstitutional-conditions doctrine. Click here to learn more about the case's background.
  • The questions presented: Is a permit exaction exempt from the unconstitutional conditions doctrine as applied in Nollan v. California Coastal Commission and Dolan v. City of Tigard, Oregon simply because it is authorized by legislation?[2]
  • The outcome: The U.S. Supreme Court vacated the California Third District Court of Appeals' judgment and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the California Third District Court of Appeals. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • April 12, 2024: The U.S. Supreme Court vacated the California Third District Court of Appeals' judgment and remanded the case for further proceedings.
    • January 9, 2024: The U.S. Supreme Court heard oral argument.
    • September 29, 2023: The U.S. Supreme Court agreed to hear the case.
    • May 2, 2023: George Sheetz, the petitioner appealed to the U.S. Supreme Court.
    • October 19, 2022: The California Third District Court of Appeals affirmed the lower court's ruling.

    Background

    Sheetz v. County of El Dorado, California is a case that involves the unconstitutional-conditions doctrine and the Takings Clause of the Fifth Amendment. The Court was asked to determine if a permit exaction is exempt from the unconstitutional conditions doctrine as applied in Nollan v. California Coastal Commission and Dolan v. City of Tigard, Oregon simply because it is authorized by legislation.[2]

    In 2016, George Sheetz applied for a permit to build a manufactured house on land he owned in the County of El Dorado, California. The County has a Traffic Impact Mitigation (TIM) Fee Program that requires any property owner who applies for a building permit to pay a traffic-impact fee. The fee is determined by location and construction type and is mandatory regardless of actual traffic impact. Despite his objections, Sheetz paid $23,420 in traffic mitigation fees to the County. Subsequently, he initiated legal proceedings against the County, contending that the fee constituted an unconstitutional condition according to the Nollan and Dolan standards.[2][3][4][5][6]

    The California Third District Court of Appeals affirmed the lower court's ruling and determined that "[t]he Nollan / Dolan test does not apply to the legislatively prescribed generally applicable development impact fee at issue here... and California law does not require an individualized or site-specific determination of reasonableness for each particular project subject to the fee."[4][5]

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    “ Whether a permit exaction is exempt from the unconstitutional conditions doctrine as applied in Nollan and Dolan simply because it is authorized by legislation.[7] ”

    Oral argument

    Audio

    Audio of oral argument:[8]




    Transcript

    Transcript of oral argument:[9]

    Outcome

    In a unanimous ruling, the Court vacated the California Third District Court of Appeals' judgment and remanded the case for further proceedings, holding that "the Takings Clause does not distinguish between legislative and administrative land-use permit conditions."[1] Justice Amy Coney Barrett delivered the majority opinion of the Court. Justice Sonia Sotomayor filed a concurring opinion, joined by Justice Ketanji Brown Jackson. Justice Neil Gorsuch filed a concurring opinion. Justice Brett Kavanaugh filed a concurring opinion, joined by Justices Elena Kagan and Ketanji Brown Jackson.

    Opinion

    In the Court's majority opinion, Justice Amy Coney Barrett wrote:[1]

    “ George Sheetz wanted to build a small, prefabricated home on his residential parcel of land. To obtain a permit,though, he had to pay a substantial fee to mitigate local traffic congestion. Relying on this Court’s decisions in Nollan v. California Coastal Comm’n, 483 U. S. 825 (1987), and Dolan v. City of Tigard, 512 U. S. 374 (1994), Sheetz challenged the fee as an unlawful “exaction” of money under the Takings Clause. The California Court of Appeal rejected that argument because the traffic impact fee was imposed by legislation, and, according to the court, Nollan and Dolan apply only to permit conditions imposed on an ad hoc basis by administrators. That is incorrect. The Takings Clause does not distinguish between legislative and administrative permit conditions.[7] ”
    —Justice Amy Coney Barrett

    Concurring opinions

    Justice Sotomayor

    Justice Sonia Sotomayor filed a concurring opinion, joined by Justice Ketanji Brown Jackson.

    In her concurring opinion, Justice Sotomayor wrote:[1]

    “ I join the Court’s resolution of the limited question presented in this case, that conditions on building permits are“not exempt from scrutiny under Nollan and Dolan just because a legislature imposed them.” Ante, at 10; see Nollan v. California Coastal Comm’n, 483 U. S. 825 (1987); Dolan v. City of Tigard, 512 U. S. 374 (1994). There is, however, an important threshold question to any application of Nollan/Dolan scrutiny: whether the permit condition would be a compensable taking if imposed outside the permitting context.


    ... The question presented in this case did not include that antecedent question: whether the traffic impact fee would be a compensable taking if imposed outside the permitting context and therefore could trigger Nollan/Dolan scrutiny. The California Court of Appeal did not consider that question and the Court does not resolve it. See ante, at 10–11. With this understanding, I join the Court’s opinion.[7]

    		”
    —Justice Sonia Sotomayor

    Justice Gorsuch

    Justice Neil Gorsuch filed a concurring opinion.

    In his concurring opinion, Justice Gorsuch wrote:[1]

    “ In short, nothing in Nollan, Dolan, or today’s decision supports distinguishing between government actions against the many and the few any more than it supports distinguishing between legislative and administrative actions. In all these settings, the same constitutional rules apply. With that understanding, I am pleased to join the Court’s opinion.[7] ”
    —Justice Neil Gorsuch

    Justice Kavanaugh

    Justice Brett Kavanaugh filed a concurring opinion, joined by Justices Elena Kagan and Ketanji Brown Jackson.

    In his concurring opinion, Justice Kavanaugh wrote:[1]

    “ I join the Court’s opinion. I write separately to underscore that the Court has not previously decided—and today explicitly declines to decide—whether “a permit condition imposed on a class of properties must be tailored with the same degree of specificity as a permit condition that targets a particular development.” Ante, at 10–11. Importantly, therefore, today’s decision does not address or prohibit the common government practice of imposing permit conditions, such as impact fees, on new developments through reasonable formulas or schedules that assess the impact of classes of development rather than the impact of specific parcels of property. Moreover,as is apparent from the fact that today’s decision expressly leaves the question open, no prior decision of this Court has addressed or prohibited that longstanding government practice. Both Nollan and Dolan considered permit conditions tailored to specific parcels of property. See Dolan v. City of Tigard, 512 U. S. 374, 379–381, 393 (1994); Nollan v. California Coastal Comm’n, 483 U. S. 825, 828–829 (1987). Those decisions had no occasion to address permit conditions, such as impact fees, that are imposed on permit applicants based on reasonable formulas or schedules that assess the impact of classes of development.[7] ”
    —Justice Brett Kavanaugh


    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, Sheetz v. County of El Dorado, California, decided April 12, 2024
    2. ↑ 2.0 2.1 2.2 U.S. Supreme Court, "22-1074 SHEETZ V. COUNTY OF EL DORADO, CA," September 29, 2023
    3. ↑ 3.0 3.1 On Petition for a Writ of Certiorari to the California Court of Appeal, Third Appellate District, "Supreme Court of the United States," accessed September 29, 2023
    4. ↑ 4.0 4.1 California Court of Appeals, Third District, El Dorado, "Sheetz v. Cnty. of El Dorado," October 19, 2022
    5. ↑ 5.0 5.1 Oyez, "Sheetz v. County of El Dorado, California," accessed January 24, 2024
    6. ↑ OPPOSITION TO PETITIONER’S PETITION FOR WRIT OF CERTIORARI, "Supreme Court of the United States," July 5, 2023
    7. ↑ 7.0 7.1 7.2 7.3 7.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 9, 2024
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 9, 2024
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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