hysical takings challenge, because "[c]onsideration of whether regulatory taking occurred would not assist in resolving whether a physical taking occurred as well." In SO holding, the Court emphasized that the two questions "exist side by side, neither encompassing the other" (Yee, 503 U.S. at 537). The Court struck a similar note in Palazzolo V. Rhode Island when it recognized that physical takings "present[ ] different considerations than cases alleging a taking based on a burdensome regulation" (533 U.S. 606, 628 (2001)). The Court reaffirmed these principles in Tahoe-Sierra Preservation Council, Inc. V. Tahoe Regional Planning Agency. The Court held that whenever a physical taking occurs, the government has a categorical duty to compensate the owner, regardless of the size of the occupation or whether the government only takes part of a larger parcel. Echoing its more extended discussion in Loretto, the Court found it appropriate to treat physical takings categorically because "physical appropri- ations are relatively rare, easily identified, and usually represent a greater affront to individual property rights." As a result, when determining whether a physical taking has occurred, the Court does not evaluate the magnitude of the economic impact on the property owner or inquire into the substantiality of the govern- mental interest underlying the regulation; any physical invasion, no matter how small, is sufficient to trigger the duty to compensate. Most importantly for our purposes, the Tahoe-Sierra Court emphasized that these differences "make ] it inappropriate to treat cases involving physical takings as controlling precedents for the evaluation of a claim that there has been a regulatory taking, and vice versa." Tahoe-Sierra thus reaffirmed the core substantive holding of Loretto by reiterating that permanent physical occupations constitute per se takings without regard to the economic impact or the public purpose served by the invasion. Tahoe-Sierra also offered the Court's plainest statement to date th