1018 Loretto v. Teleprompter Manhattan CATV Corp., 458 U.S. 419, 432 (1982) (“[A] permanent physical occupation is a government action of such a unique character that it is a taking without regard to other factors that a court might ordinarily examine.”).1019 Ark. Game & Fish Comm’n v. United States, 133 S. Ct. 511, 518 (2012).