The U.S. Supreme Court struck down a more expansive legal standard for exactions. But on remand, a California appellate court has found that the "averaging" system used in El Dorado County meets the narrower legal tests from the Nollan and Dolan cases.

Fallout from Supreme Court case on is still unclear, but there's no question that cities and counties will have to make "individualized determinations" more often, bulletproof their nexus studies, and allow more appeals. 

By taking a development fee case from El Dorado County, the U.S. Supreme Court may have the chance to narrow current limitations on exactions -- or get rid of them altogether.