In Steele v. City of Houston, 603 S.W.2d 786 (Tex. 1980), three individuals sought damages under the waiver of immunity established by Article I, section 17 when a house and belongings in it were destroyed by fire. Steele, 603 S.W.2d at 788. The fires had been set by police officers to force escaped prisoners who had taken refuge in the house to leave and be captured. Id. The supreme court rejected the lower courts' summary judgment rulings that exercise of the City's police power excused compensation and held that Steele and his tenants had alleged a compensable damage within the meaning of Article I, section 17's waiver of immunity because a taking had occurred that was intentional, neither negligent nor grounded in nuisance, and for a public use. See id. The Steele court also found the taking constituted a public use. The public use in Steele encompassed the "real or supposed" emergency--to the general public--"to apprehend armed and dangerous" escaped prisoners. Id. at 792. In Steele v. City of Houston, the plaintiffs were the owners-lessors and the lessees of a house in which three escaped convicts took refuge. Id. at 788, 789. Plaintiffs alleged the City, through its police officers, fired incendiary devices into the house in an attempt to apprehend the fugitives. The resulting fire destroyed the house and all its contents. The plaintiffs sued, alleging the destruction of their house and belongings entitled them to adequate compensation under article one, section seventeen. Id. The supreme court emphasized that its interpretation of article one, section seventeen "has moved beyond the earlier notion that the government's duty to pay for taking property rights is excused by labeling the taking as an exercise of police powers." Id. The supreme court held the plaintiffs had pleaded a lawful cause of action under article one, section seventeen. Id. at 791. As Steele illustrates, the fact that property is taken, damaged, or destroyed pursuant to the government's police power does not bar a takings claim under article one, section seventeen.