A Fistful of Dollars—Exactions and Extortion

Abstract

In the spaghetti western A Fistful of Dollars, a stranger rides into a town that is divided by a power struggle between two warring factions. After wreaking havoc with both sides, and a dramatic showdown, the man with no name rides off. It was a somewhat less dramatic but no less exciting end of the term for the U.S. Supreme Court. During the last week of June, the Court released several long‐anticipated decisions on issues of major importance: the use of race in school admissions (Fisher v. University of Texas), the validity of the preclearance provisions of the Voting Rights Act of 1965 (Shelby County v. Holder), and historic rulings on same-sex marriage (United States v. Windsor and Hollingsworth v. Perry). Somewhat overshadowed by these heavyweights—for anyone not a municipal lawyer or planner, at least—was the decision in Koontz v. St.Johns River Water Management District. Koontz, however, is likely to have as much impact within the sphere of local government law and takings jurisprudence as these other rulings will in the civil rights arena.