1. Whether the Ninth Circuit's holding that a land use permit applicant/landowner must show the government's permit condition would coerce the applicant to give up both its own property and money to establish a Fifth Amendment takings claim under the unconstitutional conditions doctrine, conflicts with this Court's decision in Koontz v. St. Johns River Management District, 570 U.S. 595 (2013)?

2. Whether the Ninth Circuit's decision is contrary to Koontz, which imposes on the land use permit applicant/landowner only the burden to show that the government imposed an unconstitutional condition that required the applicant to give up property/money for which the Fifth Amendment would otherwise require just compensation under Koontz, Dolan, and Nollan?

Whether the Ninth Circuit's holding improperly requires a land use permit applicant to show government permit conditions would coerce surrender of property and money to establish a Fifth Amendment takings claim under the unconstitutional conditions doctrine