Sheetz v. County of El Dorado

The Supreme Court held, in a unanimous opinion by Justice Amy Coney Barrett, that fees for land-use permits must be closely related and roughly proportional to the effects of the land use – the test established by Nollan v. California Coastal Commission and Dolan v. City of Tigard – even if the fees were established by legislation rather than through an individualized assessment.

In 2016, George Sheetz, a property owner in Placerville, California, applied for a permit from El Dorado county to construct a manufactured single-family home on a lot.

[2] The fee was authorized by legislation and would be utilized to "fund transportation improvements needed to accommodate growth anticipated by the county's general plan".

[13] In a concurring opinion, Justice Neil Gorsuch argued that application of the Takings Clause and Nollan/Dolan should not vary depending on the "class of property" impacted by a relevant regulation.

[2] The National League of Cities advised municipalities that imposition of such fees would now require demonstrating the relationship and relative impact of affected property developments on the community.