In Texaco, Inc. v. Short, 454 U.S. 516, 102 S. Ct. 781, 70 L. Ed. 2d 738 (1982), the Court reviewed the constitutionality of Indiana's Mineral Lapse Act. That statute provided that "a severed mineral interest that is not used for a period of 20 years automatically lapses and reverts to the current surface owner of the property, unless the mineral owner files a statement of claim in the local county recorder's office." Id. at 518, 70 L. Ed. 2d at 744. When the owners of severed mineral interests did not use the interests for twenty years and did not file a statement of claim, the surface owner of the tract brought an action seeking declaratory judgment that the mineral owners' rights had lapsed and were extinguished. The Indiana Supreme Court held that the statute was constitutional as a permissible exercise of the state's police power. The United States Supreme Court affirmed, stating, "from an early time, this Court has recognized that States have the power to permit unused or abandoned interests in property to revert to another after the passage of time." Id. at 526, 70 L. Ed. 2d at 749. The Supreme Court "has never required the State to compensate the owner for the consequences of his own neglect. . . . It is the owner's failure to make any use of the property - and not the action of the State - that causes the lapse of the property right; there is no 'taking' that requires compensation." Id. at 530, 70 L. Ed. 2d at 751-52. The courts of several other states have cited Texaco in upholding the constitutionality of their states' unclaimed property acts.