In a recent case, the U.S. Navy was found to have violated a landowner's private property rights when it purchased land outside a wildlife refuge to construct a 188-unit housing project for Navy personnel. In 2000, the plaintiff purchased 82 acres next to the Mississippi Sandhill Crane Natural Wildlife Refuge in 2000 for just shy of $1 million. Shortly thereafter, the U.S. Navy started a search for land to develop its housing project for its personnel that were stationed in Pascagoula, Mississippi. The plaintiff's property was one of the properties that the Navy targeted for its project. However, the construction of a housing project on the property required compliance with the National Environmental Policy Act of 1969 which required that the Navy prepare an Environmental Assessment. The Navy prepared an assessment and was informed that its proposal would impact the Mississippi Sandhill Crane. Consequently, the Navy was ordered by the Fish and Wildlife Service (FWS) to add 90 acres of replacement wildlife habitat to the refuge as an offset to the impact on the crane. In 2002, the Navy and the plaintiff reached an agreement for sale of the property for $1.9 million. The deal went through, but the plaintiff sued the Navy claiming that the FWS prevented the plaintiff from developing its remaining land by threatening enforcement of the Endangered Species Act. The question was whether the government's regulation of the plaintiff's property deprived the plaintiff of all productive and beneficial use of the property. The U.S. Court of Federal Claims ruled for the government because the plaintiff did not identify a "cognizable property interest." However, the Federal Circuit reversed. The ability to develop property is an identifiable property right that had been taken by the government by virtue of its purchase of the land at the lower development-restricted price. Schooner Harbor Ventures, Inc. v. United States, No. 2008-5084 (Fed. Cir. Jun. 16, 2009).