An appellate panel heard arguments in Nathan Rimmer v. City of Edmonds over whether the city's tree-replacement requirement constitutes an unconstitutional taking. City counsel argued the code limits use and is not an exaction; counsel for Rimmer said the as-applied condition failed Nolan/Dolan proportionality and the trial court's relief (including a writ of mandamus and a permit) leaves a live federal Section 1983 claim.