On June 25 2013, the Supreme Court in a 5-4 decision ruled in favor of the plaintiff in Koontz v. St Johns River Water Management District. The plaintiff (Koontz) owned a 14.9-acre tract of mostly wetlands near Orlando Florida. He wished to develop 3.7 acres and filed for a permit to dredge and fill that portion of his land. In exchange, he pledged to conserve the remaining portion of his land.
The St Johns River Water Management District required he only develop one-acre, or make improvements to government owned land nearby in exchange for a permit to be issued.