Document Type

Article

Publication Title

Wisconsin Law Review

Publication Date

1-2024

ISSN

0043-650X

Page Number

641

Keywords

assessments, The Takings Clause, development exactions

Disciplines

Law | Property Law and Real Estate

Abstract

In the spring of 2024, the United States Supreme Court decided Sheetz v. County of El Dorado. The case resolved a long-standing question: whether the constitutional rules applying to ad hoc development exactions also apply to legislated exactions. They do. It is an important case, and one that may reconfigure the financing of municipal infrastructure. This Essay examines the case through the lens of Professor Bernadette Atuahene's concept of "stategraft," or the government illegally using its regulatory power to raise money from the poor and politically powerless. This Essay compares legislative exactions to other forms of municipal finance like special exceptions and argues that they actually provide fewer opportunities for stategraft. This Essay, therefore, concludes that legislated development exactions should not be subject to heightened constitutional review.

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