A recent ruling by an Administrative Law Judge on a Manatee County in-fill project raises questions about the viability of anti-sprawl efforts in coastal communities. According to the case summary and news reports, the judge determined that the approval of a Comprehensive Plan Map change by Manatee County was not in compliance with state law because the map change increases residential development density in an area subject to coastal flooding. It is unclear what effect the ruling will have upon efforts by Manatee and Sarasota Counties to curb suburban sprawl into eastward rural lands, where development is often less expensive and easier. The counties have attempted to encourage in-fill and redevelopment projects with a combination of regulations (such as urban service boundaries) and the adoption of incentives (such as the Manatee County “encouragement zones”). The challenge and defeat of this project (led by nearby property owners opposed to the more intense development) adds another element of risk to the cost and predictability challenges policymakers have sought to reduce in an effort to encourage investment in the urban areas of coastal Florida. The timing of the ruling is significant, as Florida’s sprawl-producing growth management regulations cited in the decision are being scrutinized by the Florida Legislature, which has cited such cases as evidence of the need for reform.