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revealed a substantial connection between development and the problem to be addressed."zz <br /> Consequently, the court found "that the nexus between the fee provision here at issue, designed <br /> to further the city's legitimate interest in housing, and the burdens caused by commercial <br /> development is sufficient to pass constitutional muster."zs <br /> Even courts that decline to apply heightened scrutiny to legislatively imposed fees <br /> nonetheless apply some form of Nollan's essential nexus test. For instance, in San Remo Hotel <br /> <br /> L. P. v. City & County of San Francisco,24 although the California Supreme Court reaffirmed that <br /> legislatively imposed, ministerial impact fees are not subject to the tests in Nollan or Dolan,25 it <br /> nonetheless required that there "be a `reasonable relationship' between the fee and the <br /> deleterious impacts for the mitigation of which the fee is collected,"26 Similarly, in Holmdel <br /> Builders Association v. Township of Holmdel,~~ although the Supreme Court of New Jersey <br /> concluded that legislative fees are not subject to the heightened scrutiny of its "but-for," <br /> `Yational-nexus" test, it still required that some relationship between the development and the <br /> harm caused.28 The court essentially explained that "relationship between the private activity <br /> zz /d. <br /> z3 /d. <br /> 24 41 P.3d 87 (Cal. 2002). <br /> zs /d. at 102-03. <br /> ae Id. at 103 (citations omitted). <br /> 27 583 A.2d 277 (NJ. 1990). <br /> 28Id. at 288. <br /> 8 <br /> <br />