In 616 Croft Ave., LLC v. City of West Hollywood, (2016) 3 Cal.App.5^th 621, the court of appeal held that the City’s in-lieu affordable housing fee was not subject to the reasonable relationship test under the Nollan/Dolan line of cases.  The subject project, an 11-unit condominium development on two combined lots, was approved in 2005, but because of the economic downturn the developer did not request building permits until 2011.  During that time, the City’s in-lieu housing fee under its 2011 fee schedule had increased to $540,000.00.  The developer paid under protest, and then sued the City for a refund in 2012, arguing that the fee was an illegal “exaction”.