Abstract
Not since the 2005 term has the U.S. Supreme Court decided more than one "takings" case. This past term saw three such cases. Somewhat overlooked in the mix is the second of those cases—Horne v. United States Department of Agriculture (2013)—a case about raisins. There is nothing extraordinary about the Horne decision. In fact, the Supreme Court does not decide much of anything at all. Yet Horne is an important decision in its own right that could have a lasting impact on regulatory and land use proceedings and property rights for all involved—planners, property owners, and federal and state governments. This commentary summarizes Horne and its likely impact.