In 1999, the Florida Supreme Court rendered a decision invalidating an “Electric Utility Privilege Fee” imposed by Alachua County upon electric providers using the County’s rights-of-way to deliver electric service. The Court took the case on appeal of a circuit court order withholding validation of bonds to be issued by the County based upon such fees. Relying on a stipulated record largely devoid of factual support for a valid fee, the Florida Supreme Court rejected the fee by applying seven criteria to the record. These criteria included the relationship of the fee to (1) the extent of use of the right-of-way by the utility; (2) “the reasonable rental value of the land” occupied by the utility; (3) the local government’s costs of regulating the utility’s use of the right-of-way; (4) the cost of maintaining the portion of the right-of-way used by the utility; (5) the fee’s origin (i.e., bargained-for agreement vs. unilateral imposition); (6) the utility’s ability to avoid the fee by removing or relocating its equipment; and (7) the use by the local government of the revenue derived from the fee.