Golden v. Planning Board of Ramapo

The Court of Appeals confirmed that the State of New York's legislation enabled zoning phased growth. Writing for the court, Justice John F. Scileppi stated, "The restrictions conform to the community's considered land use policies as expressed in its comprehensive plan and represent a bona fide effort to maximize population density consistent with orderly growth."^[3] The court further stated that, because the ordinance did not prevent eventual development, its restrictions did not comprise a taking.

The case, along with Berenson v. Town of New Castle, provided the foundation for the subsequent growth management movement in the United States. The system where individual municipalities manage growth, rather than it being managed at the state level, is sometimes referred to as "the Ramapo system." It is criticized for encouraging urban sprawl and for being effectively exclusionary in areas with limited developable land.^[4] The New York Court of Appeals returned to this issue 20 years later in Long Island Pine Barrens Society, Inc. v. Planning Board of Brookhaven, where the appellate division required a cumulative environmental impact analysis over three towns for developments, which was seen as a threat to local land use authority. The Court of Appeals overturned the appellate division, disappointing environmentalists who had seen an opportunity for cumulative analysis for critical natural resource areas around the state.^[5]

Golden v. Ramapo and Construction Industry Association of Sonoma County v. The City of Petaluma, California are the basis for the use of development impact fees to finance public infrastructure throughout the United States.^[6]