In Hodel v. Irving, 481 U.S. 704 (1987), the Supreme Court addressed whether the Indian Land Consolidation Act of 1983 created an unconstitutional taking when it destroyed the rights of descent and devise which had previously attached to undivided fractional interests in land. 481 U.S. at 706-10. Congress had enacted this legislation to attempt to revise an "administratively unworkable and economically wasteful" system of administering Indian lands. Id. at 707 To further that goal, the statute destroyed the rights of descent and devise for small fractional interests of land and, instead, had those interests escheat to the tribe. Id. at 709. This, in fact, was such an "extraordinary" government action as to make it a taking, despite the indeterminancy of the other Penn Central factors (Penn Central Transp. Co. v. New York City) and the "serious public problem" which the regulation addressed. Id. at 714-18, 107 S.Ct. 2076.