In the case of Florence Dolan v. City of Tigard, 1993, the U.S Supreme Court ruled in favor of property owner Florence Dolan against the city's demand that she dedicate a portion of her land for public use as a condition for granting her permit to expand her store and parking lot. The court held that there must be a "rough proportionality" between government demands on landowners and effects caused by proposed new developments. In this case, it was found that Tigard had not shown enough evidence linking its requirement with any substantial impact caused by Dolan’s expansion plan. This ruling established an important precedent in land-use law: governments must demonstrate clear connection between their requirements for developers and impacts created by development projects before they can impose conditions on permits.

In the dissenting opinion for Florence Dolan v. City of Tigard, Justice Stevens argued that the majority's decision was inconsistent with precedent and unnecessarily complicated land-use law. He contended that there was no constitutional problem with requiring a property owner to make reasonable improvements as a condition of development approval, especially when those improvements were directly related to mitigating impacts caused by their proposed use of the property. In this case, he believed that both conditions imposed on Mrs. Dolan - dedicating land for flood control and traffic improvement - were reasonably related to her plan to expand her store and pave her parking lot which would increase runoff and traffic congestion in the area respectively. Furthermore, he criticized the majority's introduction of "rough proportionality" standard as it lacked clarity or guidance on how it should be applied in future cases.