United States v. Causby, 328 U.S. 256, 90 L. Ed. 1206, 66 S. Ct. 1062 (1946) states that the "air is a public highway," and airspace above the land "is part of the public domain"; thus, the inconveniences that flights over private property cause "are normally not compensable under the Fifth Amendment." Causby, 328 U.S. at 261, 266. To constitute a taking, the flights over private land must be "so low and so frequent as to be a direct and immediate interference with the enjoyment and use of the land." Id. at 266. In Causby, the claimants operated a commercial chicken farm and lived on their property. Id. at 259. Military aircraft, including fighters, transports, and bombers, continuously overflew the land, creating "startling" noise that caused a substantial number of the claimants' chickens to die and caused a drop in production from others. Id. Because of the overflights, the land could no longer be used as a commercial chicken farm. Id. The evidence also showed that loud noise and the planes' bright lights frequently deprived the claimants of sleep, and they became nervous and frightened. Id. The Court held that these facts established "a direct and immediate interference with the enjoyment and use of the land." Id. at 266-67.