ecedents. See, e.g., Commonwealth V. Perry, 28 N.E. 1126, 1127 (Mass. 1891) (Holmes, J., dissenting); Hadacheck V. Sebastian, 239 U.S. 394, 410-11 (1915). For more recent restatements of this rationale, see Tahoe-Sierra, 535 U.S. at 325 n. 21, and Lucas, 505 U.S. at 1014. Andrus V. Allard, 444 U.S. 51, 64-8 (1979) (eagle feathers; United States V. Sec. Indus. Bank, 459 U.S. 70, 78 (1982) (liens on real property); Ruckelshaus V. Monsanto Co., 467 U.S. 986, 1004-19 (1984) (pesticide formulas); Bowen V. Gilliard, 483 U.S. 587, 603-09 (1987) (welfare payments); Concrete Pipe & Prods. of Cal., Inc. V. Constr. Laborers Pension Trust, 508 U.S. 602, 641-45 (1993) (pension plans); Phillips V. Wash. Legal Found., 524 U.S. 156, 172 (1998) (interest on attorney trust accounts); E. Enters. V. Apfel, 524 U.S. 498, 522-37 (1998) (plurality opinion) (retiree benefits). Agins V. City of Tiburon, 447 U.S. 255, 260 (1980); Hodel V. Va. Surface Mining & Reclamation Ass'n, 452 U.S. 264, 295-96 (1981); Nollan V. Cal. Coastal Comm'n, 483 U.S. 825, 834 (1987). Constitutional Limits on the Pricing of Access to Networks longer be considered a regulation that "simply adjust[s] the benefits and burdens of economic life," but instead is more properly regarded as "the equivalent of a physical appropriation" (Lucas, 505 U.S. at 1015, 1017 (internal quotation marks omitted)). A more difficult issue arises when a restriction that falls short of eliminating all economically beneficial use nonetheless constitutes a regulatory taking. Holmes did not elaborate on the proper way to balance the interests of property owners and the government, although he did note that "this is a question of degree" (Pa. Coal, 260 U.S. at 416). The Court did not offer much additional guidance until 1978, when it issued its opinion in Penn Central Transportation Co. V. City of New York. In Penn Central, the Court recognized that, although determining whether a particular governmental action constitutes a taking is an "essentially ad hoc, factual inquir[y]," it is possib