Sheetz v. County of El Dorado

Sheetz's traffic impact fee, though imposed by county ordinance rather than administrative discretion, must satisfy the Nollan/Dolan nexus and proportionality test because the Takings Clause applies uniformly regardless of whether the exaction's source is legislative or administrative. The Court rejected El Dorado County's position that general applicability insulates ordinance-imposed permit conditions from heightened constitutional review, holding that enactment by legislative process does not convert an exaction into a permissible tax or regulation exempt from takings scrutiny. On remand, courts must examine whether the specific fee bore an essential nexus to the impact of Sheetz's development and was roughly proportional to that impact: a two-prong test the Supreme Court declined to resolve, leaving the constitutional fate of the fee itself for lower courts to determine.