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In Hearts Bluff Game Ranch v. U.S., Hearts purchased a large piece of land that the Army Corps said could be used as mitigation property for wetlands purposes. Later, the state of Texas announced it was building a water reservoir that would put Hearts under water, so it could no longer be used for wetlands mitigation. Hearts sued for uncompensated taking as the property was more valuable for mitigation than under a reservoir. The appeals held that:
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