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Property Keyed to Merrill
Koontz v. St. Johns River Water Management District
Citation:133 S. Ct. 2586
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- The Brief Prologue provides necessary case brief introductory information and includes:
- Topic: Identifies the topic of law and where this case fits within your course outline.
- Parties: Identifies the cast of characters involved in the case.
- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
- Case Key Terms, Acts, Doctrines, etc.: A case specific Legal Term Dictionary.
- Case Doctrines, Acts, Statutes, Amendments and Treatises: Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
- Brief Facts: A Synopsis of the Facts of the case.
- Rule of Law: Identifies the Legal Principle the Court used in deciding the case.
- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
The plaintiff, Koontz, sought permits to develop a section of his property from the defendant, St. Johns, based on Florida Law’s requirement that permit applicants wishing to build on wetlands offset the resulting environmental damage. Koontz offered to mitigate the environmental effects of his development proposal by giving St. Johns a conservation easement on nearly three-quarters of his property. St. Johns reject this request, and informed him that it would approve construction only if he: (1) reduced the size of his development and then gave St. Johns a conservation easement on the resulting larger remainder of property, or (2) hired contractors to make improvements to wetlands owned by St. Johns several miles away. Koontz, believing these demands excessive, declined them and filed suit under a state law providing money damages for agency action that is an unreasonable exercise of the police power constituting a taking without just compensation. Koontz won in both the District Court and The District Court of Appeals, but lost in the Florida Supreme Court. The Florida Supreme Court indicated both that Koontz claim failed because St. Johns denied his application, as opposed to accepting it with the conditions in place, and because a demand for money cannot give rise to a “takings” claim under Nollan or Dolan.
- Issue(s): Lists the Questions of Law that are raised by the Facts of the case.
- Holding: Shares the Court's answer to the legal questions raised in the issue.
- Concurring / Dissenting Opinions: Includes valuable concurring or dissenting opinions and their key points.
- Reasoning and Analysis: Identifies the chain of argument(s) which led the judges to rule as they did.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
- Policy: Identifies the Policy if any that has been established by the case.
- Court Direction: Shares where the Court went from here for this case.