Sanguinetti v. United States
United States Supreme Court
264 U.S. 146 (1924)
Where property is physically invaded by water, earth, sand, or other material, so as to effectually destroy or diminish the property’s usefulness, a taking has occurred, and compensation is owed.
It is necessary that the invasion be the direct result of a public structure or other improvement, and that the invasion be actual and permanent, amounting to an appropriation of the land and not merely an injury.