"just compensation" be paid if private property is taken for public use. This provision of the Fifth Amendment originally applied only to the federal government, but the U.S. Supreme Court ruled in the 1897 case Chicago, B. & Q. Railroad Co. v. Chicago that the Fourteenth Amendment incidentally extended the effects of that provision to the states. The federal courts, however, have shown much deference to the determinations of Congress, and even more so to the determinations of the state legislatures, of what constitutes "public use". The property need not actually be used by the public; rather, it must be used or disposed of in such a manner as to benefit the public welfare or public interest. One exception that restrains the federal government is that the property must be used in exercise of a government's enumerated powers. The owner of the property that is taken by the government must be justly compensated. When determining the amount that must be paid, the government does not need to take into account any speculative schemes in which the owner claims the property was intended to be used. Normally, the fair market value of the property determines "just compensation". If the property is taken before the payment is made, interest accrues (though the courts have refrained from using the term "interest"). Property under the Fifth Amendment includes contractual rights stemming from contracts between the United States, a U.S. state or any of its subdivisions and the other contract partner(s), because contractual rights are property rights for purposes of the Fifth Amendment. The United States Supreme Court held in Lynch v. United States, 292 U.S. 571 (1934) that valid contracts of the United States are property, and the rights of private individuals arising out of them are protected by the Fifth Amendment. The court said: "The Fifth Amendment commands that property be not taken without making just compensation. Valid contracts are property, whether the obligor be a private individual, a municipality, a state, or the United States. Rights against the United States arising out of a contract with it are protected by the Fifth Amendment. United States v. Central Pacific R. Co., 118 U. S. 235, 238; United States v. Northern Pacific Ry. Co., 256 U. S. 51, 64, 67. When the United States enters into contract relations, its rights and duties therein are governed generally by the law applicable to contracts between private