In Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992), the claimant paid just under one million dollars for beach-front property in South Carolina on which he intended to build single-family homes, a legal use under the then-existing land use regulations. 505 U.S. at 1006-08. Two years later, however, the South Carolina legislature enacted the Beachfront Management Act, which had the effect of barring the owner from building any permanent habitable structures on his property and rendering his property "valueless." Id. at 1007. He filed suit arguing that the Act effected a taking of his property without just compensation. Id. at 1009. The South Carolina Supreme Court ruled that Lucas was not entitled to any compensation because the Act was a regulation respecting the use of property designed to prevent serious public harm. Lucas, 505 U.S. at 1010. Reversing the state supreme court, the United States Supreme Court held that the recitation by a legislature of a mere "harmful or noxious use" justification was insufficient to depart from "our categorical rule that total regulatory takings must be compensated." Id. at 1026. Otherwise, "departure would virtually always be allowed." Id. Instead, when a regulation deprives the land of any economically beneficial use, the State "may resist compensation only if the logically antecedent inquiry into the nature of the owner's estate shows that the proscribed use interests were not part of his title to begin with." Id. at 1027. Such confiscatory regulations must inhere in the title itself, in the restrictions that background principles of the State's law of property and nuisance already place upon land ownership. A law or decree with such an effect must . . . do no more than duplicate the result that could have been achieved in the courts--by adjacent landowners (or other uniquely affected persons) under the State's law of private nuisance, or by the State under its complementary power to abate nuisances that affect the public generally, or otherwise. Id. at 1029. The Court departed from the balancing of "ad hoc, factual inquiries" and instead applied a categorical per se rule in cases where a regulation "denies all economically beneficial or productive use of land." Id. at 1015. Two years after landowner David Lucas had purchased property intending to build single family homes, the state legislature enacted the Beachfront Management Act which prohibited him from constructing permanent habitable structures on his property. Id. at 1008. Lucas sued, arguing the Act's prohibition prevented him from making any economically viable use of his property. Id. at 1009. The Court agreed, but recognized that such takings were an "extraordinary circumstance" and were "relatively rare situations where the government has deprived a landowner of all economically beneficial uses." Id. at 1017-18. Nonetheless, the Court stated unequivocally that "when the owner of real property has been called upon to sacrifice all economically beneficial uses in the name of the common good, that is, to leave his property economically idle, he has suffered a taking." Id. at 1019.