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. 

U.S. Supreme Court rules unanimously that California's unique exactions rule is unconstitutional. But will it really require California cities and counties to scale back on exactions?

But it was less clear how the justices would instruct local governments about how to apply narrower exaction rules to General Plans.