Key Haven Associated Enterprises, Inc. v. Florida Department of Environmental Protection
Key Haven's dredge-and-fill development of Florida Keys submerged lots was halted by state environmental authorities effective January 1, 1973, and further barred by Monroe County's 1986 comprehensive plan amendments. After DEP denied a 2018 permit application for five remaining lots, Key Haven sued for a Lucas categorical regulatory taking; the First DCA affirmed summary judgment for the State, holding the four-year limitations period began running in the 1970s-80s when the governments made final decisions prohibiting development, not upon the 2018 denial.
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