Nollan v. California Coastal Commission
Nollan v. California Coastal Commission is a landmark Supreme Court case that addresses the limits of government authority in regulating private property rights. The case arose when the Nollans sought to expand their beachfront property, and California required them to provide a permanent easement for public beach access as a condition for granting the building permit. The Supreme Court, in a narrow 5-4 decision, ruled against the California Coastal Commission, determining that there was insufficient evidence to justify the connection between the alleged public harm of restricted ocean views and the remedy proposed by the state. The Court emphasized that for a government action related to eminent domain to be valid, a substantial connection must be established between the claimed harm and the government’s required remedy. This case is significant in shaping the interpretation of property rights and the Takings Clause of the Fifth Amendment, reflecting ongoing debates about individual property rights versus public access and regulation. Dissenting justices argued for a more flexible standard that would allow for lesser connections between public benefits and government actions. The ruling has had lasting implications on how state and local governments can impose conditions on property development.
Nollan v. California Coastal Commission
Date: June 26, 1987
Citation: 483 U.S. 825
Issues: Property rights; takings clause
Significance: The Supreme Court expanded a property owner’s rights in eminent domain cases by requiring that the state show a substantial connection between the harm asserted by the state and its proposed remedy.
The Nollans owned a small beachfront house they wished to expand. As a condition for a permit, California asked the Nollans to grant a permanent beach access easement, asserting that this access would alleviate the problem of the public being unable to view the ocean. By a 5-4 vote, the Supreme Court ruled against California, finding that the connection between the public harm and the state’s proposed remedy was too tenuous, thereby limiting the broad right of eminent domain states had enjoyed in the past. The public easement, the Court argued, did not improve the public’s view of the ocean. In the majority opinion, Justice Antonin Scalia wrote that a state must show a substantial connection between the harm asserted in an eminent domain taking and the state’s proposed remedy. Justices William J. Brennan, Jr., Harry A. Blackmun, and John Paul Stevens dissented, arguing that it was wrong for the majority to insist on more than a looser, merely rational connection between the damage and the remedy in cases of this kind.
