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For example, the Supreme Court of New Jersey illustrated the applicability of this <br /> approach to non-residential development linkage fees in Holmdel Builders Association.40 There, <br /> in deciding whether to apply a "rational-nexus" test or a "reasonable relationship" test, the court <br /> found "a sound basis to support a legislative judgment that there is a reasonable relationship <br /> between unrestrained nonresidential development and the need for affordable residential <br /> development."a~ This relationship, the court explained, need only be "founded on the actual, <br /> albeit indirect and general, impact that such nonresidential development has on both the need for <br /> lower-income residential development and on the opportunity and capacity of municipalities to <br /> meet that need." Harmonizing its inclusionary zoning doctrine, the court noted that such zoning <br /> is "itself is based on that relationship.i42 <br /> On the other hand, a number of jurisdictions have strictly followed Dolan in the context <br /> of legislative monetary exactions. For example, in Town of Flower Mound v. Stafford Estates <br /> <br /> Ltd. Partnership,43 the Supreme Court of Texas narrowly held that a legislative exaction <br /> concerning off-site public improvements was properly reviewed under Dolan.44 There, the town <br /> had the discretion to grant Stafford, a developer, a variance from the exaction requirement, <br /> 40Holmdel, 583 A.2d at 288. <br /> ai /d. <br /> az Id <br /> as 135 S.W.3d 620 (Tex. 2004). <br /> as Id. a[ 622-24. <br /> 11 <br /> <br />