 Both cases involved the forced dedication of land – an easement in Nollan and a public easement and bicycle path in Dolan.Left unanswered was the question whether an exaction demand of money was subject to the nexus and proportionality tests.In Koontz v. St. Johns Water Management District, 570 U.S. 595 (2013), Coy Koontz sought permission to build a small 3.7 acre shopping center on 14.9 acres of property, much of which was wetlands.