or its administrative agency in making rate reductions" (315 U.S. 575, 603 (1942) (Black, J., concurring) (internal quotation marks omitted)). b. Regulatory Takings Regulatory takings are the second type of nonpossessory taking recognized by the Supreme Court. As Justice Holmes acknowledged in his seminal opinion in Pennsylvania Coal Co. V. Mahon, regulatory takings necessarily involve a difficult balance of interests. On the one hand, the government must have wide latitude in regulating the use of property, even if such regulation reduces the property's value. Indeed, "[g]overnment hardly could go on if to some extent values incident to property could not be diminished without paying for every such change in the general law." On the other hand, the government's ability to impose limits on the use of property "must have its limits" if the constitutional protection of property is to be meaningful. Without some restriction on the government's ability to qualify the manner in which owners can use their property, "the natural tendency of human nature [would be] to extend the qualification more and more until at last private property disappears." Thus, "[t]he general rule at least is, that while property may be regulated to a certain extent, if regulation goes too far it will be recognized as a taking" (260 U.S. at 413, 415, 416). Although the Supreme Court's regulatory takings jurisprudence originally emerged in the context of land-use restrictions, the Court has since applied the analysis to any government-imposed nonpossessory restriction on property. In the landmark decision in Lucas V. South Carolina Coastal Council, the Court squarely held what it had frequently noted in dicta in other cases6: a nonpossessory regulation may constitute a per se taking if it deprives the owner of "all economically beneficial or productive use of land." When a restriction reaches this level, it can no Although Pennsylvania Coal is generally regarded as the seminal opinion on regulatory takings, it was not without its historical ant