American Institute of Certified Planners (AICP) Practice Exam

In which case did the Supreme Court rule that land-use restrictions must have a rational nexus to the public purpose?

1. Lucas v. South Carolina Coastal Council

2. Dolan v. City of Tigard

3. Nollan v. California Coastal Commission

4. First English Evangelical Lutheran Church v. County of Los Angeles

The correct answer is: Nollan v. California Coastal Commission

The correct answer pertains to the case of Nollan v. California Coastal Commission, where the Supreme Court established the requirement that land-use restrictions must have a rational nexus to a legitimate public purpose. This case revolved around a coastal property owner who was required to provide an easement for public access to the beach as a condition for receiving a building permit. The Court held that such a condition was unconstitutional unless there was a connection between the easement requirement and the impact of the proposed development on the beach access. The ruling emphasized that if government actions, such as imposing restrictions or conditions, are to be considered valid, they must directly relate to the intended public benefit. In this case, the imposition of the easement was determined to lack a rational link to the environmental impact of the private development, thus making it an unconstitutional taking under the Fifth Amendment. Understanding this case is crucial because it helped to clarify the limitations on government power to impose land-use regulations. It established an important precedent for future cases, requiring a clear connection between land-use regulations and their stated public purposes, thereby protecting private property rights against potentially arbitrary governmental conditions.