The U.S. Supreme Court’s decision last week in Koontz v. St. Johns River Water Management District expands the holdings of Nollan v. California Coastal Comm’n, 483 U.S. 825 (1987) and Dolan v. City of Tigard, 512 U.S. 374 (1994) to provide more extensive protections to property owners faced with government-imposed land use conditions.  Nollan and Dolan hold that government exactions must have a sufficient nexus and be roughly proportional to the effects of the property owner’s proposed use